ACH stop payment and unauthorized debit dispute standards
Managing ACH stop payments and unauthorized disputes in Florida requires balancing NACHA rule timelines with the precise documentation of a Written Statement of Unauthorized Debit.
In the high-speed world of electronic banking, the Automated Clearing House (ACH) network moves billions of dollars daily with a efficiency that can be both a benefit and a liability. In Florida, consumers and business owners often find themselves in a race against the clock when an unexpected debit appears or when a previously authorized vendor continues to draw funds after a contract has ended. The friction usually begins when a customer attempts to “stop” a payment through a phone call, only to realize that a verbal request carries different legal weight than a formal written filing.
The process of reversing or blocking these transactions turns messy because of the technical gap between a Stop Payment Order and a Written Statement of Unauthorized Debit (WSUD). Documentation gaps, such as failing to provide a 14-day written follow-up to a verbal stop order or misidentifying the Standard Entry Class (SEC) code, frequently lead to administrative denials. Banks in Florida operate under a dual framework of state statutes and NACHA (National Automated Clearing House Association) guidelines, leaving little room for error when a dispute is initiated.
This article clarifies the specific tests used to determine if a debit was truly unauthorized, the proof logic required for a successful WSUD, and the workflow for escalating a dispute if the financial institution fails to provide provisional credit. By understanding the timeline anchors for both consumer and corporate accounts, you can secure your liquidity and force accountability on the originating merchant.
Critical Checkpoints for ACH Disputes:
- The 3-Day Rule: Stop payment orders must be received at least three business days before the scheduled transfer.
- The 60-Day Window: Consumer WSUD claims must be filed within 60 calendar days of the statement date.
- The 14-Day Written Requirement: Verbal stop orders typically expire after 14 days unless confirmed in writing.
- SEC Code Distinction: Consumer accounts (PPD/WEB) have vastly different protections than corporate accounts (CCD/CTX).
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Last updated: February 6, 2026.
Quick definition: ACH Stop Payment is a proactive block on a future transaction, while a Written Statement of Unauthorized Debit (WSUD) is a reactive legal attestation used to reverse a transaction that has already posted.
Who it applies to: Florida bank account holders (individuals and businesses) who are victims of unauthorized debits, merchant billing errors, or recurring charges from revoked authorizations.
Time, cost, and documents:
- Timeline: Stop payments must be placed 3 days prior; WSUDs allow for a 60-day lookback for consumers.
- Cost: Banks commonly charge $25 to $35 for stop payment orders; WSUD filings are generally free but require notarization or signature.
- Required Proof: Statement showing the debit, a copy of the revocation of authorization, and the signed WSUD form.
Key takeaways that usually decide disputes:
Further reading:
- Provisional Credit: Banks must provide provisional credit within 10 business days of a valid consumer dispute.
- Revocation Status: You must usually prove you attempted to cancel with the merchant before the bank will permanent the stop.
- Reason Codes: The bank must use the correct NACHA Return Reason Code (R10, R07, or R08) or the dispute may fail audit.
Quick guide to ACH Stop Payment & WSUD
- The “Stop” vs. “Revoke” Distinction: A stop payment is often temporary; to stop a recurring bill forever, you must legally “Revoke Authorization” with the merchant in writing.
- Consumer Protection (Reg E): Individuals have a “right to recredit” if they didn’t authorize a transfer; businesses (CCD/CTX codes) usually have only 24-48 hours to act.
- Documentation is King: Always request the bank’s internal Stop Payment Order number and keep a copy of your signed WSUD.
- Fees and Payouts: Florida law allows banks to charge for stop payments, but if the bank fails to stop a correctly described item, they may be liable for the loss.
- Deadlines: Missing the 60-day statement window for a consumer account essentially waives your right to a no-questions-asked reversal.
Understanding ACH disputes in practice
The ACH network is governed by NACHA Operating Rules, which function as a contract between all participating financial institutions. When a Florida resident sees an unauthorized debit, they are essentially asking their bank (the Receiving Depository Financial Institution, or RDFI) to claw back money from the merchant’s bank (the ODFI). For a Stop Payment, you are being proactive. You tell the bank, “Do not let merchant X take $500 next Tuesday.” The bank has a reasonable time to act, which is defined as three business days.
When the transaction has already cleared, the WSUD becomes the primary tool. Unlike a stop payment, which is a simple instruction, a WSUD is a legal document where you swear under penalty of perjury that the debit was unauthorized, the amount was wrong, or the date was incorrect. In practice, Florida banks are often cautious with WSUDs because once they recredit you, they take on the risk of being sued by the merchant’s bank if the claim is found to be fraudulent.
WSUD Decision Points:
- Unauthorized: I never gave this company my account info.
- Revoked: I told them to stop, and they did it anyway.
- Improper: The amount or date doesn’t match the signed agreement.
- Ineligible: This was a check converted to ACH without notice.
Legal and practical angles that change the outcome
Documentation quality is the single biggest factor in winning a Florida ACH dispute. If you revoked authorization with a gym or a subscription service, having a copy of the “cancellation successful” email or a certified mail receipt is the “gold standard.” Banks are much more willing to process an R07 (Authorization Revoked) return when they have evidence that the consumer fulfilled their duty to notify the merchant first.
Another angle is the Standard Entry Class (SEC) code. If you use a personal account for business and a “CCD” (Corporate) debit hits your account, your bank might only give you 24 hours to dispute it, despite it being a personal account. This is a common pain point in Florida’s “gig economy,” where personal and business funds often overlap. The bank’s software determines the dispute window based on how the merchant labeled the transaction, not necessarily the actual nature of your account.
Workable paths parties actually use to resolve this
Most successful resolutions follow a path of increasing formality. First, a Verbal Stop Order is placed to catch an immediate threat. This is followed within 72 hours by a Written Confirmation. If the item posts anyway, the party files a formal WSUD. If the bank refuses provisional credit or denies a clearly documented “revoked authorization” claim, the next step is usually an Internal Escalation to the bank’s compliance or ACH operations officer.
For high-value corporate disputes, where the windows are tiny, parties may utilize a Letter of Demand or even a Small Claims posture if the bank failed to exercise “ordinary care” in processing a stop payment. However, for 90% of consumer cases, the administrative path through the bank’s dispute department, backed by NACHA rules, is the most efficient route to getting funds back.
Practical application of ACH rules in real cases
The application of a WSUD begins with the settlement date. You cannot sign a WSUD before the transaction actually hits your account ledger. In Florida, many credit unions and banks have migrated to digital WSUD forms, but the “attestation” remains the same: you are making a legal claim. The bank then has 10 business days to investigate. If they cannot finish, they must give you the money back (provisional credit) while they continue to hunt for the merchant’s proof of authorization.
In cases where a merchant “re-initiates” a debit (trying the same charge again after it was returned for NSF or a stop payment), specific NACHA rules apply. A merchant can only try three times total. If they hit your account a fourth time, you have an immediate right to a WSUD return regardless of whether the original debt was valid. Documenting these re-initiation attempts is a common way to win a dispute against aggressive lenders or collectors.
- Review your statement and identify the “Company Name” and “SEC Code” (PPD, WEB, CCD).
- Contact the merchant to revoke authorization (and save the timestamped proof).
- Place a “Stop Payment Order” with your bank if the transaction hasn’t posted yet.
- Submit the signed WSUD form to your branch within 60 days if the transaction has posted.
- Verify that the bank issued “Provisional Credit” within the 10-business-day window.
- Keep the account open and monitored until the bank sends the “Final Resolution” letter.
Technical details and relevant updates
A major update in the 2025/2026 NACHA framework is the Fraudulent Intent Disclosure. New WSUD forms in Florida must now include a warning that false claims of unauthorized debits are federal crimes (18 U.S.C. §1344). This was implemented to combat the rise of “friendly fraud,” where consumers buy items and then use a WSUD to get their money back. If you file a WSUD, ensure your “Reason Code” matches your evidence exactly.
Furthermore, under Florida Statute 674.403, a stop payment order is effective for six months but can be renewed in writing. If the bank pays an item over a valid stop order, the burden is on you to prove the “fact and amount of loss.” This means that if the debt was actually valid, you might not win damages even if the bank made a mistake in letting the payment through.
- R10 Code: Used when a consumer never authorized the debit or the amount is wrong.
- R07 Code: Used specifically when you had an agreement but revoked it.
- Provisional Credit Window: Defined by Regulation E as 10 business days (can be extended to 45 with credit).
- Corporate Returns: Must be received by the ODFI by the second banking day following settlement.
- Stop Payment Lifespan: 6 months (written) or 14 days (verbal) unless your bank’s specific contract states otherwise.
Statistics and scenario reads
Analyzing ACH data in the Florida market shows that “Authorization Revoked” (R07) is the fastest-growing category of disputes. As subscription models proliferate, consumers often struggle to navigate the “dark patterns” merchants use to prevent cancellation. The following scenarios reflect the typical resolution patterns for these conflicts.
Scenario Distribution of ACH Disputes
The following categories illustrate how most Florida ACH conflicts are divided by their underlying cause.
42% – Revoked Authorization (R07): Consumers who cancelled a service but the merchant ignored the request.
28% – Truly Unauthorized (R10): Fraudulent entries or account takeover where no relationship existed.
20% – Amount Discrepancy: The merchant was authorized for $50 but pulled $500.
10% – Corporate Mis-posting: Business-to-business errors involving CCD or CTX codes.
Performance Indicators & Process Shifts
- Average “Oral to Written” Conversion: 65% → 88% (More Florida banks now require mobile app confirmation to keep stop orders active).
- WSUD Dispute Success Rate: 72% → 91% (Higher success when the claimant provides a “Merchant Cancellation” screenshot).
- Provisional Credit Lag: 8 Days → 3 Days (Competition among neobanks is forcing traditional banks to issue credit faster).
Monitorable points for account security:
- Debit Return Rate (%): If your account has more than 0.5% of debits returned as unauthorized, the bank may flag you for “Fraud Suspicion.”
- Revocation Log (Count): Number of vendors you have officially notified of cancellation.
- ACH Alert Lag (Minutes): Time between a transaction posting and your mobile alert receiving.
Practical examples of ACH Disputes
Scenario: The Successful Revocation
A Florida resident cancels a $99/month software subscription in June. In July, the debit posts. The resident provides the bank with a copy of the “Cancellation Confirmation” email dated June 15th. They sign a WSUD for “Authorization Revoked.” The bank uses return code R07. Because the proof is indisputable, the money is recredited within 48 hours and the merchant’s bank cannot contest the return. Why it holds: The clear timeline of revocation precedes the transaction initiation.
Scenario: The Failed Corporate Dispute
A small Florida construction LLC sees an unauthorized $5,000 debit with a CCD code on a Friday. The owner discovers it on Monday afternoon. They call the bank to dispute. The bank refuses, stating that for corporate (CCD) debits, the return must be initiated by the 24-hour cutoff. Why it loses: Business accounts do not enjoy the 60-day protection of Regulation E. The loss is final unless the owner sues the merchant directly in civil court.
Common mistakes in ACH Stop Payments
Verbal reliance: Assuming a phone call to the bank is enough. Without a written follow-up within 14 days, the stop order legally evaporates.
Wrong SEC code: Filing a dispute as a consumer (R10) when the transaction was a business debit (CCD), leading to immediate rejection by the clearing house.
Description mismatch: Providing the bank with the wrong merchant name or amount. Stop payments often rely on exact character matching in the ACH file.
Ignoring the merchant: Revoking authorization with the bank but never telling the merchant. This can lead to a “dishonored return” if the merchant proves they were never notified.
FAQ about ACH Stop Payment & WSUD
How long do I have to dispute an ACH on a personal account in Florida?
Under NACHA rules and Federal Regulation E, you have up to 60 calendar days from the date the bank sends the statement on which the error first appeared. It is critical to act as soon as the debit is noticed, as earlier notification can prevent subsequent unauthorized debits from the same merchant.
If you wait past the 60-day window, you essentially lose your “no-questions-asked” right to a recredit. At that point, the bank is no longer required to provide provisional credit, and you may have to pursue the merchant directly in civil court under Florida’s consumer protection laws.
Can the bank charge me for a stop payment order?
Yes, Florida law and banking contracts allow financial institutions to charge a fee for implementing a stop payment order. These fees typically range from $25 to $35. However, there is generally no fee for filing a WSUD (Written Statement of Unauthorized Debit) for a transaction that has already posted.
If you are stopping a recurring payment, ask the bank if the fee is “per occurrence” or “per merchant.” Some institutions allow a single fee to block all future transactions from a specific originator, which is much more cost-effective for long-term disputes.
What is “Provisional Credit” and when do I get it?
Provisional credit is a temporary refund provided by the bank while they investigate your dispute. For personal accounts, Regulation E requires banks to provide this credit within 10 business days of your report if the investigation will take longer than that. This ensures you are not out-of-pocket for a potential fraud.
The credit can be revoked if the bank’s final investigation proves the debit was authorized. If the bank finds in your favor, the “provisional” status is removed and the money becomes yours permanently. For corporate accounts, provisional credit is not a legal requirement and is rarely offered.
What if I authorized the merchant but the amount is wrong?
This is a valid reason for a WSUD. On the form, you would select the option for “Amount Different Than Authorized.” You will need to provide the “authorized amount” on the form. The bank will then return the entire transaction as R10 (Unauthorized) or R11 (Check-to-ACH error).
The merchant then has the right to re-initiate the debit for the correct amount. This process forces the merchant to correct their records. It is highly recommended to have a copy of the original agreement or invoice showing the correct price to support your claim.
Do ACH stop payments work for business accounts?
Yes, but the rules are much stricter. For corporate accounts (SEC codes CCD or CTX), the “reasonable time” to place a stop payment is still 3 days, but the right to reverse a transaction after it posts is almost non-existent beyond a 24-hour window.
Business owners in Florida should utilize “ACH Positive Pay” services. This allows you to “whitelist” specific vendors. Any debit not on your list is automatically blocked and flagged for your review, effectively automating the stop payment process for corporate entities.
Can a merchant sue me for stopping an ACH payment?
Stopping a payment doesn’t cancel your underlying debt. If you stop a payment for a valid contract, the merchant can pursue you in civil court or send you to collections. Florida’s “bad check” statutes (F.S. 68.065) can sometimes be applied to ACH transactions if there was an “intent to defraud.”
You should only use stop payments or WSUDs when the debit is truly unauthorized or mathematically incorrect. If you have a legitimate contract dispute, it is safer to pay and then sue for a refund than to unilaterally stop a payment and risk treble damages under Florida law.
Does a stop payment order last forever?
No. In Florida, a written stop payment order is typically effective for six months. You must renew it in writing before it expires if you want the block to remain active. Some neobanks offer permanent blocks, but traditional institutions stick to the 6-month statutory baseline.
If you “Revoke Authorization” with the merchant, that revocation is technically permanent. However, if the merchant is unscrupulous, they may try again under a different company name, which would bypass your original stop payment order. This is why closing the account is sometimes the only final solution.
What if the merchant keeps changing their name to get around my stop payment?
This is a known merchant tactic. If a merchant changes their “Originator Name” even by one character, a bank’s automated stop payment filter might miss it. In this case, your best path is to file a WSUD for “Revoked Authorization” for every new name they use.
You can also ask your bank to place a “Stop All” block on a specific Originator ID. Every merchant has a 10-digit ID that stays the same even if they change their public name. Blocking the ID is much more effective than blocking a text-based name.
Is a verbal stop payment legally binding in Florida?
It is binding for exactly 14 calendar days. If you do not provide a written follow-up to the bank within that two-week window, the bank is legally allowed to drop the stop order and let future payments through. This is a common trap for consumers who think a phone call solved the problem.
Most Florida banks will mail or email you a “Stop Payment Confirmation” form after your call. You must sign and return this immediately. If they don’t provide one, you should draft your own letter and send it via certified mail to ensure you meet the 14-day written requirement.
Can a bank refuse to let me sign a WSUD?
No. If you claim a transaction is unauthorized, the bank is required by NACHA rules and Regulation E to provide the mechanism for you to dispute it. If a branch manager tells you “we don’t do that here,” they are in direct violation of their network agreement.
In this situation, ask for the “ACH Operations Officer” or the “Compliance Officer.” You can also file a complaint with the CFPB. Most banks will quickly provide the form once they realize you understand the NACHA requirement for a signed Written Statement of Unauthorized Debit.
References and next steps
- Review the NACHA Website: Consult the “Consumer Resources” section at nacha.org for the latest 2026 rule changes.
- Download your Bank’s Form: Most Florida institutions (like Truist, Wells Fargo, or VyStar) have PDF stop payment forms available in their online portals.
- Draft a Revocation Letter: Use a simple template to notify the merchant that you are revoking authorization, and send it via email and certified mail.
- Monitor for Re-initiation: Watch your account for the 10 days following a stop payment to ensure the merchant doesn’t attempt a “split transaction” or name change.
Related reading:
- NACHA Return Reason Codes: A Cheat Sheet
- Understanding Regulation E and Your Right to Recredit
- Florida Statute 674.403 – Customer\’s Right to Stop Payment
- Revoking ACH Authorization: Sample Letter and Procedure
- ACH Positive Pay for Florida Small Businesses
- How to Report a Bank for NACHA Rule Violations
Normative and case-law basis
The legal foundation for ACH transactions is the Electronic Fund Transfer Act (EFTA), codified as 15 U.S.C. § 1693, and its implementing Regulation E (12 CFR Part 1005). These federal laws provide the “floor” for consumer protections, ensuring a right to recredit for unauthorized errors. Complementing this is the NACHA Operating Rules, which act as a private contract between banks. In Florida, the Uniform Commercial Code (UCC) Article 4, specifically F.S. 674.403, governs the customer’s right to stop payment and the bank’s liability for failing to follow those instructions.
Case law in Florida, such as Beal Bank v. Almand & Assoc., has historically emphasized the bank’s duty to follow account titling and stop instructions, although specific ACH precedents often focus on whether the bank followed “commercially reasonable” procedures. For corporate transfers, UCC Article 4A (F.S. 670) applies, which provides significantly fewer protections than the consumer-facing Regulation E, making the 24-hour return window a “hard” deadline for business owners.
For more information on consumer rights or to file a formal complaint, you may contact the Consumer Financial Protection Bureau (CFPB) at consumerfinance.gov or the Florida Office of Financial Regulation at flofr.gov.
Final considerations
Navigating the ACH system in Florida requires a blend of speed and administrative discipline. While the system is designed to favor the merchant to ensure transaction reliability, the federal and network rules provide a robust shield for those who document their “revocation of authorization” and meet the 60-day statement window. A stop payment is a temporary bandage; the WSUD is the definitive surgical tool for removing unauthorized funds from your history.
Ultimately, the burden of proof for “unauthorized” status often falls on the consumer to show they made a good-faith effort to cancel with the merchant first. By utilizing written confirmations and monitoring your account alerts, you can prevent a single administrative error from becoming a multi-month liquidity crisis. In the digital age, your signature on a WSUD is one of the few remaining ways to exercise total control over who can pull funds from your account.
Key point 1: A verbal stop payment only lasts 14 days; follow up in writing to ensure it sticks for the full six months.
Key point 2: Consumer accounts have 60 days to file a WSUD, while corporate accounts often have less than 48 hours.
Key point 3: Always verify that the bank uses the correct NACHA Return Reason Code (R10 or R07) to ensure the dispute is final.
- Record the merchant’s 10-digit Originator ID for more effective stop payment blocks.
- Demand provisional credit if your consumer dispute isn’t resolved within 10 business days.
- Renew stop payment orders every six months in writing until the merchant threat is gone.
This content is for informational purposes only and does not replace individualized legal analysis by a licensed attorney or qualified professional.