|
Stop
Payments and Reg E (cont'd)
One
thing to keep in mind is the effect on the Receiver Account.
For example, assume that the Receiver has a health club
payment he/she wants stopped because there is a problem getting the
correct amount to pay. The RDFI needs to know what the Receiver is
actually requesting. To learn this, questions must be asked such as,
“Should just this payment be stopped or all future
payments?” If the receiver decides to stop all future payments
from the health club and a Stop Payment is set up, all future health
club payments to this source will be stopped.
If
the Receiver resolves the issue with the health club at a later date
and starts payments again, those will be automatically stopped.
Therefore, if the Receiver decides to stop all future payments for a
given source he/she must be advised if he/she wants the stop payment
removed. Otherwise, the
RDFI will be unaware of the decision.
In
summary, the new Rule aligns the ACH system more closely with Reg E
in the following ways:
·
It
eliminates the six-month and two week time periods after which a
stop payment order placed by the consumer lapses;
·
It provides
that, where the stop payment order applies to more than one debit
entry, the order remains in effect until all such entries have been
stopped;
·
It permits
the financial institution to require, in cases where the Receiver
desires to block all future payments related to a specific
authorization/Originator, that the Receiver confirm in writing that
the Receiver revoked the authorization with the Originator;
·
It does not
alter the manner in which the financial institution returns a stop
payment via the ACH network.
For
more information, see
the Frequently Asked Questions on the NACHA website at
http://admin.nacha.org/userfiles/File/ACH_rules/Jan1310%20telelseminar
%20questions%20-%20_jan%2029,%202010_.pdf.
|
