Written Statement of Unauthorized Debit (WSUD): Filing and Denials

A written statement of unauthorized debit, usually called a WSUD, is a signed declaration you give your bank to dispute an ACH withdrawal you never properly authorized. It does two jobs at once: under NACHA Operating Rules it is the paperwork your bank needs to send the transaction back through the ACH network, and under the federal Electronic Fund Transfer Act it feeds the error-resolution process that can force your bank to return the money. How much of that money you actually recover depends heavily on how quickly you report the problem, with your liability climbing from $50 to unlimited depending on the timing.¹

What Counts as an Unauthorized Debit

Federal law defines an unauthorized electronic fund transfer as one initiated by someone other than you, without your actual permission, and from which you received no benefit.² That covers the obvious case of a company you’ve never heard of pulling money from your account. It also covers subtler situations: a merchant charging more than you agreed to pay, a debit posting earlier than the authorized date, or a subscription that keeps billing after you cancelled.

A few things fall outside the definition. If you gave someone your card or account access and they misused it, the transfers aren’t considered unauthorized until you tell your bank the person is no longer allowed to use the account. Transfers you initiated with fraudulent intent don’t qualify either, and bank errors are handled under a separate error category.²

Report Fast — Your Liability Depends on It

The single most important thing about an unauthorized ACH debit is how quickly you tell your bank. Report promptly and federal law caps your liability at $50.¹

If the problem involved a lost or stolen card or access device and you wait more than two business days after learning of the loss, your liability can rise to $500 for unauthorized transfers occurring during the delay.¹ Wait more than 60 days after your bank sends the statement showing the unauthorized transfer, and you risk losing the ability to dispute the charge at all under Regulation E.³ Unauthorized transfers occurring after that 60-day window carry no federal liability cap. The clock runs from when the bank sends the statement, not when you open it, so review statements as they arrive.

Information the Form Asks For

Before you request a WSUD form from your bank, pull the transaction details off your statement. The form will ask for:

Your full legal name as it appears on the account
The complete account number where the debit posted
The exact dollar amount of the disputed withdrawal
The date the transaction settled on your account
The name of the company or person that initiated the debit, as shown on your statement

These fields match the standard template published by NACHA.⁴ Most banks and credit unions use their own version of the form, available through customer service or the online banking portal. The wording differs; the core information does not.

Picking the Right Reason Code

The form asks you to identify why the debit was improper. Your bank uses that answer to apply the correct NACHA return code when sending the transaction back through the ACH network. The main categories:

Unknown company, return code R10. You don’t recognize the company, have no relationship with it, or never authorized any debit from your account.⁵
Entry doesn’t match the authorization, return code R11. You did authorize a debit, but the amount is wrong or the debit posted earlier than agreed.⁵
Authorization revoked, return code R07. You previously authorized the company to debit your account, cancelled that permission, and the company debited you anyway.⁵

The right category matters. An R10 return tells the ACH network the company had no right to touch your account at all. An R11 signals a narrower dispute over the terms of an existing authorization. The wrong code can slow the process or trigger pushback from the originating company’s bank.

Signing the Statement

The WSUD is a legal declaration. You sign it under penalty of perjury, swearing that the information is true and that the debit was genuinely unauthorized.⁶ Filing a false WSUD to reclaim money you actually owe can lead to criminal fraud charges or civil penalties. Banks take the signature seriously because they are financially exposed if the return is later disputed by the originating bank.

Some banks require the signature to be notarized. That’s a bank policy, not a federal requirement. If notarization is required, state-set fees generally run from $2 to $25 per signature.

Many banks also accept electronic signatures through their secure online portals. Under the federal E-Sign Act an electronic signature is valid as long as you intended to sign and the bank’s system can link the signature to the document.⁷ Before you sign electronically, the bank must tell you about your right to receive paper records and your right to withdraw consent for electronic communications.

Stop Payment or WSUD?

People confuse these two tools constantly, and using the wrong one wastes days you may not have. A stop payment order is preventive. You place it before a debit hits your account, and for recurring ACH debits you need to request it at least three business days before the next scheduled charge. A WSUD is reactive. You file it after the unauthorized debit has already posted and settled, and it must be dated on or after the settlement date of the disputed entry.

A subscription you cancelled is about to charge you next week? Stop payment. That charge already hit yesterday? WSUD. A stop payment on a transaction that already settled won’t get your money back, and a WSUD on a future transaction that hasn’t posted won’t be accepted.

How to Submit the Form

You can start the dispute either orally or in writing. A phone call to customer service starts the investigation clock. But if you report by phone, the bank can require you to follow up with a signed written statement within ten business days. If it asks and you don’t send it, the bank has no obligation to provisionally credit your account.⁸ Send the signed WSUD as quickly as possible either way.

Create a paper trail when you deliver it. Hand-deliver it to a branch and request a stamped copy, mail it certified with return receipt, or upload it through the secure online portal. Keep a copy of the signed form and proof of the date the bank received it. That date is your evidence if a timeline dispute comes up later.

The hard deadline is 60 days from the date your bank sent the statement showing the unauthorized debit.³ Miss it and your bank has no legal obligation to investigate or return your money.

What Happens After You File

Your bank has ten business days from receiving your error notice to investigate and decide whether the debit was unauthorized.³ If it confirms the error within that window, it must correct it within one business day of that finding. Many straightforward disputes end here.

If the bank needs more time, it can extend the investigation to 45 days, but only if it provisionally credits your account for the disputed amount within the first ten business days.³ The provisional credit puts the money back so you can use it while the investigation continues. The bank must notify you within three business days of completing the investigation.

Investigation windows stretch for a few situations: accounts less than 30 days old, transfers initiated from outside the United States, and point-of-sale debit card transactions all get a 90-day investigation window, with 20 business days before provisional credit is required for new accounts.⁹

If the Bank Denies Your Claim

A denial isn’t the end. Ask for the bank’s written explanation and the documents it relied on. Read them carefully. Banks sometimes reject claims because of incomplete paperwork or a misclassified return code rather than a genuine finding that the debit was authorized. If the problem is procedural, resubmitting with corrected information may fix it.

If you still believe the bank was wrong, file a complaint with the Consumer Financial Protection Bureau. The CFPB forwards the complaint to the bank, and companies generally respond within 15 days; complex cases can take up to 60.¹⁰

When the Bank Doesn’t Follow the Rules

Banks that miss their Regulation E obligations face real exposure. If your bank fails to provisionally credit your account within the required timeframe and either didn’t conduct a good-faith investigation or had no reasonable basis for concluding the debit was authorized, you can recover treble damages.⁸ Statutory damages for an individual claim run from $100 to $1,000, so the trebled range is $300 to $3,000, plus actual damages and attorney’s fees.¹¹ Treble damages also apply when a bank knowingly concludes your account wasn’t in error despite evidence the other way. Between the statutory floor, the multiplier, and fee-shifting, it is realistic for a consumer rights attorney to take a strong case.

A Note on Business Accounts

Everything above applies to personal consumer accounts. The Electronic Fund Transfer Act only covers accounts held by natural persons for personal, family, or household purposes.² Business accounts get none of Regulation E’s protections: no mandatory investigation timelines, no provisional credit, no 60-day dispute window. Under NACHA rules, business-to-business ACH debits typically have a return window of just two banking days from settlement. Your bank can still file a WSUD and attempt an extended return, but the originating bank is under no obligation to accept it. Businesses need to monitor accounts daily, because a debit caught on day three may already be unrecoverable through the ACH network.

1
Office of the Law Revision Counsel. 15 USC 1693g – Consumer Liability
2
Office of the Law Revision Counsel. 15 USC 1693a – Definitions
3
eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors
4
Nacha. ACH Operations Bulletin 1-2023 – Update to Sample Written Statement of Unauthorized Debit
5
Nacha. Differentiating Unauthorized Return Reasons
6
Office of the Law Revision Counsel. 28 USC 1746 – Unsworn Declarations Under Penalty of Perjury
7
Federal Deposit Insurance Corporation. X-3 The Electronic Signatures in Global and National Commerce Act (E-Sign Act)
8
Office of the Law Revision Counsel. 15 USC 1693f – Error Resolution
9
Consumer Financial Protection Bureau. 12 CFR 1005.11 – Procedures for Resolving Errors
10
Consumer Financial Protection Bureau. Submit a Complaint
11
Office of the Law Revision Counsel. 15 USC 1693m – Civil Liability