![]() ![]() In addition, an account validation service or method could supplement its primary validation method with others, such as an ACH prenotification or micro-transaction, in an effort to come closer to 100% coverage. the use of other compensating controls.the historical experience of fraud on “no hit” responses with the service being used and,.the originator’s history with returns for invalid account information and fraud.the risks associated with the purpose of the transaction being initiated.Such facts and circumstances can include: ![]() What is “commercially reasonable” should be assessed by the parties within the full context of all the relevant facts and circumstances. An account validation service or method might be commercially reasonable for a specific set of facts and circumstances, even if it does not cover 100% of potential accounts or account validation attempts. Nacha does not consider a fraudulent transaction detection system that does not include an account validation component as sufficient. Since the concept of commercial reasonableness is dependent on each customer’s particular situation and how it compares to similarly-situated Originators, each Originator, in consultation with its own attorneys, risk department, or other advisors, will need to determine which account validation method meets the commercially reasonable standard for its own facts and circumstances. Similarly, for others, an account with a proven history of prior successful payments may prove a sufficient means for validation for use of the account with a new WEB authorization. As an example, use of a third-party that provides scoring information on the account status might be determined by some Originators to be a commercially reasonable option. Other options not listed above may also provide a commercially reasonable means to test an account for ACH use. Examples of methods to validate an account may include, but are not limited to, the use of a Prenotification Entry, ACH micro-transaction verification, use of a commercially available validation service provided by either an ODFI or a third-party, and use of account validation capabilities or services enabled by APIs. ![]()
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