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NACHA Update: Return for Questionable Transaction Rule

6/24/2019 - By Janice Weisz, AAP

Effective June 21, 2019, NACHA expanded the use of Return Reason Code R17 – File Record Edit Criteria by allowing RDFIs to indicate within a return that the original transaction was questionable or part of anomalous activity.  Please note that RDFIs will continue to still use R17 for returns that involve required field errors.

Under the Return for Questionable Transaction Rule, RDFIs may (but are not required) use Return Reason Code R17 – File Record Edit Criteria to indicate that the RDFI believes the entry containing invalid account information was initiated under questionable circumstances.  This use of R17 is optional at the discretion of the RDFI.  RDFIs that elect to use R17 for this purpose are required to use the description “QUESTIONABLE” in the Addenda Information field of the return.  This description in an R17 return will differentiate returns that appear to be suspicious to the RDFI from those due to routine account number issues.


RDFIs that choose to use R17 to flag questionable/suspicious entries may experience an increase in manual processing of those returns.  RDFIs must ensure the software system will include the descriptive information of “QUESTIONABLE” within the Addenda Information field of the return.


ODFIs may see an increase in R17 returns.  ODFIs and their Originators should be aware of the new messaging conveyed via the R17 Return Reason Code and may wish to review such returns more closely. 

Visit NACHA’s website to learn more. 

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

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, internal audit, NACHA compliance, and other consulting services to the firm’s financial institution industry clients.

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