This tool was developed to help Receiving Depository Financial Institutions (RDFIs) better understand how they may be able to recover funds from an Originating Depository Financial Institution (ODFI). The tool addresses both Extended Returns and Warranty Claims. The deadline for when they can file a Warranty Claim will change with the implementation of the new Limitation on Warranty Claims rule effective June 30, 2021. This tool reflects the impact of the new rule.
This tool is not intended to provide legal advice. Financial institutions are encouraged to obtain their own legal counsel regarding their obligations under the Nacha Operating Rules and other applicable legal and regulatory requirements.
In determining consumer liability or the ability to recover from an ODFI, an RDFI should consider its obligations under Regulation E (which Nacha cannot advise on), as well as warranty claims that can be made under the Nacha Rules. Further, as a reminder, a warranty claim is not the same as a return and does not guarantee the return of funds.