9/10/2021 - By Janice Weisz, AAP
Rule Overview
Effective September 17, 2021, in conjunction with the Standing Authorizations Rule and Oral Authorizations Rule, the Other Authorization Issues Rule includes other modifications and reorganizations of the general authorization rules for purposes of Clarity, Flexibility and Consistency.
For Clarity, the Other Authorization Issues Rule will:
For Flexibility, the Other Authorization Issues Rule will:
For Consistency, the Other Authorization Issues Rule will:
Minimum Standards
An authorization for a debit entry to the consumer account of the receiver must, at a minimum, include:
Impact to Participants
ODFIs and Originators
ODFIs and originators should review authorizations to ensure they meet the standards of “readily identifiable” and “clear and readily understandable terms”. These participants should also review and revise consumer debit authorization language to ensure that it includes the minimum standards.
RDFIs
RDFIs should have no impacts to their receipt and posting of entries.
For more information, you can also visit Nacha's website.
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. Janice currently is an Accredited ACH Professional (AAP) and conducts risk-based Nacha compliance audits and provides ACH-consulting services to the firm’s financial institution industry clients.
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