Advance America's response to my ACH revocation

At ApplyAdvanceAmerica.com, we understand how important it is to our customers to have access to payday advance funds as soon as possible after an advance is approved. That's why we fund our advances through an electronic funds transfer provided by the automated clearing house ('ACH') network. We also provide for repayment of advances via ACH. Because our advances are single payment advances (that is, we advance a sum of money that is to be repaid in a lump sum), we are permitted to require ACH repayment in accordance with the Federal Electronic Funds Transfer Act ('EFTA').

Under the EFTA, a lender cannot require a consumer to repay a loan by means of preauthorized electronic funds transfers as a condition to approving the consumer's loan. The term 'preauthorized electronic funds transfer' is narrowly defined by the EFTA to mean 'an electronic funds transfer authorized to recur at substantially regular intervals.' As explained by the Federal Reserve Staff in its official commentary to the EFTA, 'Creditors may not require repayment of loans by electronic means on a preauthorized, recurring basis.' 12 C.F.R. 205, Supplement I ???????? Official Staff Commentary, at 10(e) (1) (Loan Payments). As a one-time payment, the repayment of a ApplyAdvanceAmerica.com advance is not encompassed by the EFTA's definition of 'preauthorized electronic funds transfer,' and is therefore permitted under the EFTA.


Are they correct, or are they trying to side-step the rules a bit?


Don't they still have to abide by this (?):


907. Preauthorized transfers
(a) A preauthorized electronic fund transfer from a consumer's account may be authorized by the consumer only in writing, and a copy of such authorization shall be provided to the consumer when made. A consumer may stop payment of a preauthorized electronic fund transfer by notifying the financial institution orally or in writing at any time up to three business days preceding the scheduled date of such transfer. The financial institution may require written confirmation to be provided to it within fourteen days of an oral notification if, when the oral notification is made, the consumer is advised of such requirement and the address to which such confirmation should be sent.
(b) In the case of preauthorized transfers from a consumer's account to the same person which may vary in amount, the financial institution or designated payee shall, prior to each transfer, provide reasonable advance notice to the consumer, in accordance with regulations of the Board, of the amount to be transferred and the scheduled date of the transfer.
[Codified to 15 U.S.C. 1693e]