3/1/2023 - By Sallie O'Brien, AAP, APRP
Are you a Bank, Credit Union or Third-Party Sender that originates Micro-Entries on behalf of your customers?
With Micro-Entries (Phase 2), risk management requirements will be applied to all Originators of ACH Micro-Entries. Enforcement of this requirement begins March 17, 2023.
Micro-Entries are often called test entries, penny deposits or micro-deposits. These entries help the Originator verify if an account is open and active. These entries are under $1, and the credit amount must be equal to or greater than the debit amounts transmitted. These entries must be settled simultaneously.
Existing screening requirements explicitly state that “account validation” is part of a “commercially reasonable fraudulent transaction detection system.”
As a reminder, additional Micro-Entry rules went into effect on September 16, 2022.
Questions?
Click here for more information on this Nacha Rules requirement. Please contact our Financial Instutions Consulting practice if you have any questions or need assistance with a Nacha compliance review, assessment of risk, or consulting.
About the Author | Sallie O'Brien, AAP, APRP
Sallie is a senior consultant in the Financial Institution Advisory Group at Saltmarsh, Cleaveland & Gund. She has over 19 years of experience working with financial institutions. Sallie specializes in risk-based Nacha compliance audits and provides ACH-consulting services to the firm’s financial institution industry clients. Prior to joining Saltmarsh, Sallie was a senior director of education at a regional consulting firm where she provided payment education and Nacha compliance programming for third-party providers.
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