Several California credit unions have reported receiving suspicious large-dollar ACH debit entries. All entries were over $100,000 ($150,000 to $250,000) and were sent to both existing and non-existing credit union accounts. US Bank was the ODFI in all instances.
NACHA amended its operating guidelines in 2024 to allow for the return of questionable transactions:
Credit unions should evaluate suspicious ACH entries for reporting on a Suspicious Activity Report. A SAR may be required even if the credit union or the credit union member did not suffer a loss.
Credit unions are permitted under Regulation P to share information with a third party outside of privacy regulations “To protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability.”
For more information, email Heather Line.
Your League-member benefits include the Compliance Hotline — providing exclusive access to dedicated compliance experts:
Using the above phone number and email address, you can gain access to a knowledgeable team that’s ready to address all your credit union’s compliance inquiries — promptly and efficiently. With the Compliance Hotline, you can proactively respond to impromptu questions and issues by getting clarity and insight on technical topics that normally slow you down. We want to help you unlock the full potential of your League membership by leveraging the resources and support you need to navigate the complex world of compliance effortlessly. We’re ALWAYS just a phone call or email away!
Additionally, other League-member compliance resources include:
For more information, email Lisa Quaranta.
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