I agree. However, I believe the OSI to 1005.11(c)(3) indicates that the Bureau discourages any fee on assertion of errors as it may prohibit consumers from invoking their error resolution rights.
This would be different from a stop pay. If you receive a stop pay on a recurring ACH I don’t any reason that you couldn’t charge your normal fees. It’s when it becomes an error or fraudulent that you shouldn’t charge a fee for stopping or correcting such activity as required by Reg E.