ACH Specialist Series: Electronic Payment Fraud: When Is Your Institution Liable?

One risk area that has exploded in recent years involves electronic payment fraud – and both ODFIs and RDFIs are experiencing the fallout. ACH fraud can involve consumer or commercial accounts. Do you know which regulations apply to each? What are the return deadlines? What are your institution’s responsibilities to the accountholder? Can you afford to miss this important program?

• Distinguish between the ODFI’s and RDFI’s liabilities for ACH payment fraud
• Explain your institution’s responsibilities when acting as the ODFI versus the RDFI
• Define the return deadlines for ACH fraud for consumer and corporate accounts under the Nacha rules
• Understand how to bring a breach of warranty claim against the ODFI after the return deadlines
• Identify when Reg E conflicts with the Nacha rules and when your institution must reimburse consumer accounts for ACH fraud
• Employ new ways to encourage the RDFI to return funds to your institution after the ACH fraud is identified