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ACH: Limitations of Warranty Claims 2022


Event Details*
Tuesday, February 22, 2022
2:00 - 3:30 pm ET
Webinar; 1.8 AAP/APRP CEU Eligible
Learning Level: Intermediate

Event Registration**
Member Price: $225.00
Non-Member Price: $325.00

On June 30, 2021, NACHA implemented a new ACH Rule called Limitation on Warranty Claims. This new rule limits the ODFI and Originators’ liability for unauthorized ACH debits. The rule introduced three claim windows: two for consumer claims, and one for business claims.

An RDFI can, under this rule, recover funds that resulted from unauthorized ACH entries, but these claims must be initiated outside of the network if the settlement date of the entry(ies) is outside the deadline for an R10 or R11 return.

The rule does not prescribe responses from the ODFI, which continues to create confusion and frustration among participants.

Using common NEACH member questions, this interactive, intermediate-level session explores issues like:
• How long does the ODFI have to respond to an RDFI claim?
• If transactions have occurred for years, what is the RDFI required to investigate and what is the consumers liability? Why?
• What is the ODFIs liability for unauthorized debits against a business account?
• What should an RDFI do if the ODFI fails to respond?
• What are some incorrect responses ODFIs are trying?
• What are some suggested best practices for RDFIs attempting to recover funds?
• What are some suggested best practices for ODFIs to reduce exposure?
• What “evidence” is required for an RDFI to initiate the claim?
• Does this Rule replace existing Breach of Contract state law?

Grab your account holder claim response procedures and join us to explore the process and participant responses under this new Rule!

Takeaway! Attendees will receive the updated Breach of Warranty sample letter created by NEACH and law firm Stinson, LLC.

Using case studies, and applicable laws including EFTA/Reg. E and UCC, attendees will:
• Define key terms and the 3 claim windows
• Compare the ACH Rule with laws
• Evaluate participant liability for unauthorized ACH debit entries
• Clarify the portions of the new Rule causing the most confusion
• Apply the Rule to real-life cases
• Examine common NEACH member questions

Rayleen M. Pirnie, BCJ, AAP, CERP, Director, Risk & Fraud, NEACH
Sandy Ortins, AAP, APRP, NCP, Senior Vice President, Membership, NEACH


• AAPs
• ACH Coordinator
• Associate Members
• Audit
• Electronic Banking
• Financial Institutions
• Operations
• Product Management
• Reg E
• Risk/Compliance
• Training Director

You might also like:
• UCC Series: ACH
• Sticky Situations: Reg E Compliance Tips (2-pt series)
• ACH Fraud: The Rules and Beyond 2022

*Please note that the access information will be sent to you in a separate email upon receipt of payment. Access information and support are only provided during normal business hours.
** This event is part of the NEACH Education Club. Members who join the Club save $75 off the cost of this event.

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