A.)   Because WEB debits are authorized electronically a proof of authorization for any WEB debit requires both the authorization language and a record of authentication that serves as the equivalent to the Consumer’s signature for a written authorization.

Chapter 48 of the Nacha Operating Guidelines provides some important reminders for all Originators of WEB entries, including ODFIs who act as Originators for their own WEB debit entries.

For Authorizations: All authorizations must meet the minimum requirements of Nacha Operating Rule2.3, including that they be in writing.In the context of a WEB debits, this means that the authorization language is visible on a screen or visual display and is available for the Receiver to print out and retain, if so desired.

In regards to Authentication: The authentication method must identify the Receiver and demonstrate the Receiver’s assent to the authorization. When a Receiver is providing authorization via the Internet or a Wireless Network, the "authentication of the authorization is strongest when the authorization and the authentication occur simultaneously or nearly simultaneously."

Proof of Authorization for WEB debits consists of both a record of the authorization and a record of the authentication of the authorization. The record of authorization should also include "documentation that provides transaction details including Receiver information."