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We consequently suggest two amendments that are additional the ACH Rules:

We consequently suggest two amendments that are additional the ACH Rules:

We advice two modifications that could strengthen the authorization further conditions:

NACHA guidelines should require that a copy must be obtained by an ODFI of every authorization through the Sender before processing an ACH deal. Because of the present degree of punishment of this ACH system, NACHA must not permit ODFis to rely entirely regarding the representations of this Originator. In the event of a Dispute, Require the RDFI to acquire a duplicate associated with Authorization through the ODFI

Also, NACHA guidelines should need, in case a consumer disputes a transaction as unauthorized, that the RDFI have a copy associated with the authorization through the ODFI and offer it into the customer. As written, the guidelines just enable the RDFI to request these records.