FAQs - Northwest Clearing House Association

THE NORTHWEST CLEARING HOUSE ASSOCIATION

Frequently Asked Questions

Can we return CCD or CTX late?

Originator or ODFI's failure to respond to repeated NOC's?

Returning Social Security items for a deceased client?

What are the time frames to return an item, dishonor a return, contest a dishonored return?

What do we do if a consumer client received an unauthorized ACH Debit?

How can we set up onsite training by NWCHA at our institution?

Can we return CCD or CTX item late?
Pursuant to Article 6 Subsection 6.1.2 of the NACHA Operating Rules, "Each return entry must be received by the RDFI's ACH Operator by its deposit deadline for the return to be made available to the ODFI no later than opening of business on the second banking day following the Settlement date of the original entry."

However, if your corporate client has received an unauthorized transaction, as an RDFI you may choose to call the ODFI to see if they will accept a R31 "Permissible Return Entry". If the ODFI is unwilling to accept the late return your client will need to attempt to have the transaction returned outside of the ACH Network.

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Originator or ODFI's failure to respond to repeated NOC's?
Pursuant to Article 6 Subsection 6.3.2 "The Originator must make the changes specified in the NOC or corrected NOC within 6 banking days of receipt of the NOC information or prior to initiating another entry to the Receiver's account, whichever is later."

Originators failure to respond to NOC's is the number one rules violation received by NACHA. If you are experiencing this problem it is strongly recommend that you call the ODFI. If you have contacted the ODFI and are still unable to resolve the problem you have the right to file a rules violation with NACHA.

If you would like to file a rules violation log onto http://www.nacha.org/2002_fines_form.pdf

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Returning Social Security items for a deceased client?
Pursuant to the Federal Green Book, "A RDFI is liable for ALL benefit payments received after the death or legal incapacity of a recipient or death of a beneficiary unless the RDFI meets the qualifications for limiting its liability"

Upon learning of the death of one of your clients you should immediately return all government transactions that have posted to that clients account after the date of death. For a complete description of how to limit you liability for federal items attend one ofo ur Government Payment Seminars

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What are the time frames to return an item, dishonor a return, contest a dishonored return?

Return Entries:
Pursuant to Section 6 Subsection 6.1.2 "Each return entry must be received by the RDFI's ACH Operator by its deposit deadline for the return entry to be made available to the ODFI no later than opening of business on the second banking day following the Settlement date of the Original item."

Dishonor of Return Entries:
Pursuant to Section 6 Subsection 6.2.1 "The ODFI must transmit a dishonored return entry complying with appendix 5 to its ACH Operator within five banking days after the Settlement Date of the return entry."

Contesting of Dishonored Returns by RDFI:
Pursuant to Section 6 Subsection 6.2.2 " A contested dishonored return must be transmitted to the ACH Operator within two banking days after the Settlement Date of the dishonored return entry"

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What do we do if a consumer client received an unauthorized ACH Debit
Pursuant to Section 8.7 Subsection 8.7.1 " An RDFI receiving the Written Statement Under Penalty of Perjury (Affidavit) described in subsection 7.6.4 may transmit an adjustment entry to its ACH Operator in the amount of the unauthorized entry referred to in the affidavit."

The RDFI must transmit the adjustment entry to its ACH Operator by its deposit deadline to be made available to the ODFI no later then opening of business on the banking day following the sixtieth calendar day following the Settlement Date of the original entry.

You must also keep a copy of the WSUPP and provide the ODFI with a copy, if the request is in writing and received within one year of the adjustment entry.

For more information on creating an WSUPP see your 2005 NACHA Operating Rules, and consult your financial institutions legal department.

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How can we set up onsite training at our institution with NWCHA?
The Northwest Clearing House Association is happy to offer onsite training. We will willingly work with you to create a schedule of half or full day sessions custom built to meet your institutions needs. For a complete list of classes offered by NWCHA check our Seminars & Education page, and contact us at (206) 622-7846

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