Unauthorized Transactions – Reg E vs Nacha Operating Rules

Unauthorized transactions come in many different forms, when returning using Reg E or the Nacha Operating Rules can be confusing. Discussion will include what, why, and when while processing unauthorized returns. The trainer will define the limits of liability and who is liable for what amount while providing some real-life scenarios. Details on the error resolution process with Reg E for consumer notification to the financial institution, research time involved, and the timing of providing provisional credit; included will be guidelines on the “what if” there is no error, and providing notice to the consumer, and any overdraft protection relating to that provisional credit being reversed. Included will be outlining the ACH return process, when using the ACH network is appropriate, and the paperwork/forms needed.  Recent Rule changes affecting Nacha compliance when sending unauthorized ACH Returns using Return Reason Codes R10 vs. R11 are included.

• Timeframes for consumer when reporting errors to the financial institution
• Consumer liability and responsibility for unauthorized transactions
• Financial Institution liability and responsibility when handling errors to consumer accounts
• Identify what is covered by Regulation E and what is not covered
• List details on “What is an Error” in Reg E and the Nacha Operating Rules
• Define the Error Resolution Process including timeframes

Outline the process when returning unauthorized transactions in the ACH network, including when to use R10 vs. R11 (due to recent Rules changes)

As a financial institution, you have responsibilities and liabilities under Regulation E and the Nacha Operating Rules for your consumer accounts when there are unauthorized transactions.   
Regulation E contains an error resolution process for electronic payments posting to consumer’s accounts.  Returning Unauthorized ACH transactions and the logistics when doing so will be covered in detail, including the addition of a repurposed Return Reason Code R11 and when to use R10 vs R11.
Included in this session is an opportunity for attendees to apply the basics of Regulation E and the error resolution timeframes while comparing with ACH processes when returning unauthorized transactions. all while remaining compliant with the Nacha Operating Rules will be demonstrated as the trainer walks attendees through some real-life scenarios.
 

• Bank operations staff
• New employees in the payments industry
• Bank managers and payment professionals
• CEO’s and CFO’s
• Risk, Compliance and Audit personnel
• Aspiring AAP’s and current AAP’s for AAP CE Credits 

Donna K Olheiser, AAP, is the vice president of Education Services and founder of Dynamic Mastership, LLC. Donna is an enthusiastic and energetic Certified Master Trainer with over 14 years’ training experience. She has designed and facilitated over 100 training sessions each year with her expertise being the rules for companies and financial institutions when processing specifically ACH electronic payments, then scheduling the training events to facilitate/deliver the material through a variety of venues (webinars, teleseminars, in-person workshops, including regional and national conferences). Donna has over 24 years of experience in the financial services industry which includes 9 years’ experience as the education service director at a Regional Payments Association (RPA), where she managed and facilitated the entire education program for nearly 800 financial institution members. Prior to that, Ms. Olheiser spent 14 years in various departments with the Federal Reserve Bank of Minneapolis and also holds the Accredited ACH Professional (AAP) designation (achieved in 2004).