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Nacha's ACH Contact Registry Rule - Phase 2

6/21/2021 - By Janice Weisz, AAP

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, if you have any questions or need assistance preparing for these new Nacha Rules, email me or a member of our Financial Institutions Team so we can help. 

About the Author | Janice Weisz, AAP

Janice is a consultant in the Financial Institution Advisory Group at Saltmarsh, Cleaveland & Gund. Janice has been working with financial institutions since 2001 with an emphasis on operations, compliance, audit and internal controls. She currently provides ACH compliance, NACHA compliance, internal audit and other consulting services to the firm’s financial institution industry clients. Connect with Janice on LinkedIn!


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