KEN KIRSCHENBAUM, ESQ
ALARM - SECURITY INDUSTRY LEGAL EMAIL NEWSLETTER / THE ALARM EXCHANGE
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is new cc or ach authorization needed for account or cc update changes 
October 9, 2026
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is new cc or ach authorization needed for account or cc update changes
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Ken,
    We get a signed credit card/ach form for all new projects.  If the card is compromised or changed in the future, must we obtain a new CC/ACH form?  Could an email be sent to the customer asking them to confirm card ending xxxx will be used in place of card ending in xxxx going forward?  We are in Massachusetts.
JA
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Response
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    Massachusetts has adopted the Massachusetts Uniform Electronic Transactions Act (MUETA), which generally recognizes electronic records and electronic signatures as legally valid when the parties intend to conduct business electronically.
    That means an email from the customer confirming, “Please use card ending 1234 instead of card ending 5678 going forward,” could potentially serve as evidence of authorization if you can authenticate the customer and retain the record appropriately.
    That said, from a documentation and risk management perspective, it is preferable to obtain a new signed Credit Card/ACH Authorization Form whenever a customer changes the payment method originally authorized.  Doing so ensures our records accurately reflect the currently authorized card and provides the clearest support in the event of a future dispute.  Accordingly, while an email confirmation may be acceptable as supplemental documentation, our recommended practice is to obtain an updated signed authorization form whenever the card on file changes.
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Ken Kirschenbaum,Esq
Kirschenbaum & Kirschenbaum PC
Attorneys at Law
200 Garden City Plaza
Garden City, NY 11530
516 747 6700 x 301
ken@kirschenbaumesq.com
www.KirschenbaumEsq.com