ACH claims are always given Reg E protection in QFD, regardless of transaction age or the span of transactions. Under § 1005.6(b)(3), consumers are protected for the first statement, plus 60 days, and can be held liable for any subsequent transactions. Even still, § 1005.6(b)(4) requires that timeframe be extended for "extenuating circumstances", though no definition is provided. Since QFD is unable to determine a cause for delay, all transactions are considered protected. There are configuration settings that can be modified to ensure some automation is stopped on aged transactions, however if a user fails to take action by Reg45, QFD will resolve the claim and send a Paid letter to the accountholder. |