Quote:
Originally Posted by jact
Could you explain "acceptable means" so I can ensure that ours is?
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Since I'm not the one who can state exactly what is "acceptable" and what is not (we'll leave that to the regulators), an easy way to figure it out is to ask yourself two basic questions...
1) What is being done to validate that the ABA and Account numbers are correct, before presenting them to the ACH network??? (a quick glance at your reason codes on your Returns can clue you in on this. If they contain mostly "invalid account", "unable to locate", "account closed", "unauthorized", etc.... then guess what?!)
2) What is being done to authenticate or verify that the consumer is who they say they are???
Simply put, if you can use any ABA & Account number and/or randomly use anybody's name & address (without having to verify any pertinent, personal info) and the transaction gets processed... then chances are, you are NOT using acceptable means of authentication!
Hope this helps.
