|
Q.) Our business account holder just noticed several unauthorized ACH debits (CCDs) on their September bank statement and contacted us to find out what we will do about it. We told them the transactions were too old to be returned and that they would need to contact the company that debited their account to arrange for a refund. They don’t recognize the company and feel we should handle the situation. Is there anything we can do?
A.) The ACH Rules state that unauthorized corporate transactions must be returned within two banking days of receipt. Your disclosures for new business accounts should reflect the account holder’s obligation to report these transactions to you in a timely manner. That said, the Originating Depository Financial Institution (ODFI) warrants that all ACH transactions are properly authorized, so you can ask the ODFI to provide proof of the debit authorization. You may ultimately find that someone in the company did authorize these debits; or, the Originator may find that there was an error on the authorization (i.e. account number transposed). In that case, the ODFI should give you permission for a late return(s). If so, the appropriate return code would be R31 / Permissible Return Entry (CCD and CTX only). See page OR143 in your 2020 ACH Rule Book for additional details.
We also recommend that you take this opportunity to remind the account holder of their responsibilities and to review their disclosures. And, if you offer Positive Pay or Debit Block services, this is a great time to make a sale!
|
