Resolving Errors and Unauthorized Payments: Reg E vs. Nacha Operating Rules
March 31, 2026
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Resolving errors and unauthorized ACH transactions can be one of the most challenging responsibilities for financial institutions. Determining whether Regulation E or the Nacha Operating Rules apply, understanding strict timeframes, and managing consumer notifications and liability all require precision and confidence.
This in-depth, scenario-based session explains exactly what to do, why it matters, and when each rule applies. Whether an unauthorized ACH return falls within Nacha timeframes or must be handled under Regulation E, you will learn how to navigate the process correctly from start to finish.
The session covers consumer error reporting requirements, investigation and research timelines, provisional credit obligations, and the steps to take when no error is found. You will also review ACH return processes, including when use of the ACH network is appropriate, required documentation, and how overdraft protection interacts with provisional credit reversals.
Why You Should Attend
Financial institutions have significant responsibilities and potential liability under both Regulation E and the Nacha Operating Rules when handling unauthorized transactions involving consumer accounts.
Missteps can result in regulatory criticism, financial loss, and consumer complaints. This session provides practical guidance to help you confidently apply the rules, meet required deadlines, and understand where liability falls in real-world situations.
Using real life scenarios, the presenter will walk through how Regulation E error resolution timelines align and differ from ACH return requirements, including proper use of Return Reason Codes R10 and R11.
What You Will Learn
Participants will gain a clear understanding of:
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Timeframes for consumers to report errors to their financial institution
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Consumer liability and responsibility for unauthorized transactions
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Financial institution liability and responsibilities when handling errors to consumer accounts
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What transactions are covered by Regulation E and what are not
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How Regulation E and the Nacha Operating Rules define an error
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The complete Regulation E error resolution process, including investigation and response timeframes
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Requirements for providing provisional credit and reversing it when no error is found
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The process for returning unauthorized ACH transactions, including proper use of R10 versus R11
Throughout the session, examples and demonstrations will show how to apply both Regulation E and the Nacha Operating Rules in common and complex scenarios.
Who Should Attend
This session is ideal for:
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ACH and payments operations staff
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Bank operations managers and payment professionals
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Risk, compliance, and audit personnel
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CEOs and CFOs seeking a better understanding of liability exposure
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New employees in the payments industry
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Aspiring and current Accredited ACH Professionals (AAPs) seeking continuing education credits
Presenters:
Donna Olheiser
Donna K Olheiser, AAP, is the vice president of Education Services and founder of Dynamic Mastership, LLC. She is an enthusiastic and energetic Certified Master Trainer with over 14 years’ experience. She has over 23 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). Her extensive knowledge, enthusiasm, and passion for transferring payment processing knowledge using the adult learning theory is remarkable and has helped many payment professionals perform daily operational tasks including exception processing while remaining compliant with the NACHA Operating Rules. She uses scenarios and examples to bring the learning home, easy to comprehend and apply to real-life day-to-day ACH
March 31, 2026