regulation e VS ach Flashcards
What year was the Electronic Funds Transfer Act implemented?
1978
This party provides guidelines for reporting & resolving disputes regarding unauthorized transactions?
Regulation E
This party allows an extended return timeframe for unauthorized debit entries?
Nacha Operating Rules & Guidelines
This party is governed by the CFPB 2011
Regulation E
This party includes accounts for checking, savings, or other consumer asset accounts.
Regulation E
This party includes accounts for checking, savings, loan accounts and general ledger?
ACH Rules
This party does not include any account held by a financial institution under a bona fide trust agreement (IRA or HSA accounts)
Regulation E
This party includes all Standard Entry Class Codes, including RCK
ACH Rules
This party includes accounts that are non-bank P2P payment provider who may directly or indirectly hold a prepaid or mobile account whose primary function is to conduct P2P transfers. (Venmo, Cash App)
Regulation E
This party includes all ACH Standard Entry Class Codes except RCK & XCK
Regulation E
This party has a two year retention on WSUDs
Regulation E
This party has a one year retention on WSUDs
ACH Rules
This party warrants that the RDFI has a signed WSUD prior to extended return?
ACH Rules
This party warrants that the FI may not delay initiating or completing an investigation pending receipt of a WSUD.
Regulation E
For preauthorized recurring EFTs an Oral or written notice must be received within how many days before the scheduled date of the transfer?
This applies to both Reg E and ACH
Notice must be received at least 3 business days.
If a stop payment is made orally, FI may require written confirmation within how many days?
This applies to both Reg E and ACH
Written confirmation may be required within 14 days.
This type of entry is an order or request for the transfer/withdrawal to/from a deposit or loan account of a receiver
ACH Entry
What is the consumer’s liability for reporting an unauthorized transfer for Regulation E.
Within 60 days of transmittal of statement to avoid liability for subsequent transfers.
What is the limit length of time in which an RDFI would be permitted to make a claim against ODFI’s authorization warranty for an entry to a consumer account?
Time limit would cover 2 time periods:
1. First 95 days
2. Last 2 years
What is the limit length of time in which an RDFI would be permitted to make a claim against ODFI’s authorization warranty for an entry to a non-consumer account?
Time limit would be one year from settlement date of entry.
What is the time limit for disputes for Regulation E?
There is no statute limitation. However, FI is not required to comply with error resolution procedures if consumer notifies FI after 60 Calendar days from statement availability.
What is the time limit for disputes for ACH Rules?
- Limited ODFI warranty that entry is authorized.
- 60 day extended return timeframe
- Late returns allowed upon ODFI approval
- RDFI right to request copy of auth.
What is Regulation E error resolution timeline.
- Determine if error occurred within 10 business days (20 business days for new account)
- Correct within 1 business day
- Report results within 3 business days.
- may take up to 45 days (90 days if IAT or POS)
What is Regulation E obligation for provisionally crediting an amount for an alleged error? (If Timely)
Inform consumer within two business days that a credit will be deposited into their account.
