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Nacha Update: Providing Relief to Banks & Credit Unions

4/1/2020 - By Janice Weisz, AAP

Signature Requirements for Written Statements of Unauthorized Debit

The Nacha Rules require an RDFI to accept a consumer’s Written Statement of Unauthorized Debit (WSUD) and also require that the WSUD be signed or similarly authenticated.  

Nacha issued ACH Operations Bulletin #5-2020 on March 27, 2020, stating that in light of the current need for many RDFIs to reduce on-site staffing levels, and the physical distancing requirements that currently apply to many people, Nacha will not enforce the signature/similar authentication requirement until further notice. 

Additional things that RDFIs can do and should understand:

  • RDFIs can direct consumers to report unauthorized debits by remote channels – e.g., online and by telephone. RDFIs that have the ability for consumers to similarly authenticate signatures by these remote channels should continue to do so.
  • Before submitting a return, RDFIs should continue to take reasonable care to have the consumer verify claims of unauthorized ACH debits consistent with signature-based procedures to avoid improper returns.
  • The existing extended return timeframe of 60-days for claims of unauthorized debits to consumer accounts still applies.

Proofs of Authorization, Source Documents, and Written Statements of Unauthorized Debit

In light of the current need for organizations to reduce on-site staffing levels, Nacha issued an ACH Operations Bulletin to provide temporary relief from deadlines for delivery of certain records that are required under the Nacha Rules.  

Under the Nacha Rules:

  • An ODFI must provide an RDFI with proof of a Receiver’s authorization (PoA) within 10 Banking Days of receipt of the RDFI’s request. 
  • An ODFI must provide a copy of a Source Document for an ARC (Account Receivable) or BOC (Back Office Conversion) Entry, or an item for an RCK (Re-presented Check) Entry, within 10 Banking Days of an RDFI’s request.
  • An RDFI must provide an ODFI with a copy of a consumer Receiver’s Written Statement of Unauthorized Debit (WSUD) within 10 Banking Days of receipt of the ODFI’s request. 

Nacha understands that these deadlines may cause a challenge in the current environment. For the duration of the National Emergency concerning the coronavirus, Nacha will refrain from recommending enforcement penalties for cases in which a PoA, Source Document/item, or WSUD is provided after the existing 10 Banking Day time frame but within 20 Banking Days.  

Nacha encourages ODFIs and RDFIs to cooperate and to fulfill these obligations under the Rules as quickly as circumstances permit.  ODFIs and their Originators should be mindful that utilizing a longer timeframe for providing PoAs could lead to an increase in returns based on claims of unauthorized entries.  However, the relief provided by Nacha will allow ODFIs, their Originators, and RDFIs to adapt to the new operating environment without risk of enforcement penalties. 

QUESTIONS?

Staying in compliance can be challenging, if you have any questions or need assistance, email me or a member of our Financial Institutions Team so we can help. 

Visit our COVID-19 RESOURCE HUB for ongoing updates and information. Due to the ever-changing nature of this event, you should always consult a professional.

About the Author | Janice Weisz, AAP
Janice is a consultant in the Financial Institution Advisory Group at Saltmarsh, Cleaveland & Gund. Janice has been working with financial institutions since 2001 with an emphasis on operations, compliance, audit and internal controls. She currently provides ACH compliance, NACHA compliance, internal audit and other consulting services to the firm’s financial institution industry clients.


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