The Nacha Rules require an RDFI to accept a consumer’s Written Statement of Unauthorized Debit (WSUD), and also require that the WSUD be signed or similarly authenticated.
In light of the current need for many RDFIs to reduce on-site staffing levels, and the physical distancing requirements that currently apply to many people, Nacha will not enforce the signature/similar authentication requirement until further notice.
Additional things that RDFIs can do and should understand:
RDFIs can direct consumers to report unauthorized debits by remote channels – e.g., online and by telephone. RDFIs that have the ability for consumers to similarly authenticate signatures by these remote channels should continue to do so;
Before submitting a return, RDFIs should continue to take reasonable care to have the consumer verify claims of unauthorized ACH debits consistent with signature-based procedures to avoid improper returns;
The existing extended return timeframe of 60-days for claims of unauthorized debits to consumer accounts still applies.