Nacha's ACH Contact Registry Rule - Phase 2

6/21/2021

Phase 1 of Nacha’s Automated Clearing House Network (ACH) Contact Registry Rule, which became effective July 1, 2020, required all participating depository financial institutions (DFIs) to register contact information with Nacha for personnel or departments responsible for ACH operations and fraud/risk management. To stay compliant with Nacha, all participating DFIs were required to complete the registration by October 30, 2020.  Nacha provided an additional 9-month grace period until July 31, 2021, to ensure broad communication of this requirement before failure to register would be enforced through the National System of Fines.

Under Phase 2, on August 1, 2021, Nacha’s enforcement authority for this rule becomes effective. ACH participating DFIs that do not register their contact information with Nacha may be subject to a Rules enforcement proceeding and Class 2 violation fines. In situations involving a Class 2 Rules violation, the ACH Rules Enforcement Panel may levy a fine against the respondent participating DFI in an amount up to $100,000 per month until the problem is resolved. 

If you would like more details regarding Phase 1, I addressed Nacha’s ACH Contact Registry Rule Phase 1 requirements in this article.

For more information, you can also visit Nacha’s website.

Questions?

Staying in compliance can be challenging, so if you have any questions or need assistance, email paymentadvisors@saltmarshcpa.com or a member of our Financial Institutions Team so we can help. 

About the Bank Advisors

The Bank Advisors at Saltmarsh have provided audit, tax and consulting services to a wide range of financial institutions since our founding in 1944, making it the firm’s largest specialty practice and industry of focus. Our Financial Institution Advisory Group has the talent, expertise and insight to help you and your institution thrive. Our team members are also industry leaders who have the knowledge and experience to provide you with unparalleled service and guidance.


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