Unauthorized Transactions – Reg E vs Nacha Operating Rules

Unauthorized transactions reach a financial institution in many forms, and deciding whether to handle them under Regulation E or the Nacha Operating Rules is a common source of confusion and risk.

This 90-minute Reg E vs Nacha webinar explains what each set of rules covers, why the difference matters, and when each applies. Using real-life scenarios, the trainer sets out the limits of liability for the consumer and the financial institution, and who is liable for what amount.

You'll follow the Reg E error resolution process step by step: the consumer's notice, the time allowed for research, when provisional credit must be given, what to do when no error is found, and how reversing provisional credit affects overdraft protection. The session also outlines the ACH return process, when returning through the ACH network is appropriate, the forms you need, and recent Nacha rule changes on Return Reason Codes R10 and R11.

• Know the timeframes consumers have to report errors to the financial institution
• Explain consumer liability and responsibility for unauthorized transactions
• Explain the financial institution's liability and responsibility when handling errors on consumer accounts
• Identify what Regulation E covers and what it doesn't
• Define “what is an error” under Reg E and the Nacha Operating Rules
• Follow the error resolution process, including its timeframes
• Return unauthorized transactions through the ACH network, including when to use R10 vs R11 after recent rule changes

• The different forms unauthorized transactions take
• What Regulation E covers and what it doesn't
• What counts as an error under Reg E and under the Nacha Operating Rules
• Limits of liability: who is liable for what amount
• The Reg E error resolution process: consumer notice, research time and provisional credit
• What to do when no error is found, notices to the consumer and overdraft protection when provisional credit is reversed
• The ACH return process: when to use the ACH network and the forms you need
• Recent Nacha rule changes: Return Reason Codes R10 vs R11
• Real-life scenarios

Every financial institution has responsibilities and liabilities under Regulation E and the Nacha Operating Rules when unauthorized transactions post to consumer accounts. Getting the rules confused can mean missed deadlines, wrong liability decisions and returns that break Nacha rules.

This session covers the Reg E error resolution process for electronic payments and the logistics of returning unauthorized ACH transactions in detail, including the repurposed Return Reason Code R11 and when to use R10 vs R11. The trainer walks you through real-life scenarios so you can apply Reg E timeframes alongside the ACH return process and stay compliant with both.

• Bank operations staff
• New employees in the payments industry
• Bank managers and payment professionals
• CEO’s and CFO’s
• Risk, Compliance and Audit personnel
• Aspiring AAP’s and current AAP’s for AAP CE Credits 

Donna K Olheiser, AAP, is the vice president of Education Services and founder of Dynamic Mastership, LLC. Donna is an enthusiastic and energetic Certified Master Trainer with over 14 years’ training experience. She has designed and facilitated over 100 training sessions each year with her expertise being the rules for companies and financial institutions when processing specifically ACH electronic payments, then scheduling the training events to facilitate/deliver the material through a variety of venues (webinars, teleseminars, in-person workshops, including regional and national conferences). Donna has over 24 years of experience in the financial services industry which includes 9 years’ experience as the education service director at a Regional Payments Association (RPA), where she managed and facilitated the entire education program for nearly 800 financial institution members. Prior to that, Ms. Olheiser spent 14 years in various departments with the Federal Reserve Bank of Minneapolis and also holds the Accredited ACH Professional (AAP) designation (achieved in 2004).