Since social distancing policies and stay-at-home orders have changed the way we do business, the National Automated Clearing House Association (NACHA) issued ACH Operations Bulletin #5-2020 that suspends the requirement for receiving depository financial institutions (RDFI) to accept written statements of unauthorized debits that are signed or similarly authenticated by consumers until further notice. The NACHA rules require an RDFI to accept a consumer’s written statement of an unauthorized debit that is signed or similarly authenticated when an unauthorized debit is posted to the consumer’s account.

While NACHA is suspending the signed or similarly authenticated written statements of unauthorized debits, NACHA provided additional guidance for RDFIs in light of this change. NACHA permits RDFIs to allow consumers to report unauthorized debits through other channels, such as online and by telephone. NACHA also recommends RDFIs continue to have consumers verify claims of unauthorized ACH debits with “signature-based procedures” to avoid fraud. Finally, NACHA includes a statement that the “existing extended return timeframe of 60-days for claims of unauthorized debits to consumer accounts still applies.”

In light of this operations bulletin, RDFIs should take note and implement appropriate processes and procedures that allow consumers to submit statements of unauthorized debits through remote channels that allow consumers to sign or similarly authenticate the record.