ODFI Responsibility to Keep its ACH Clients Informed of Nacha Rules

2/22/2022 - By Janice Weisz, AAP

Nacha Rules state that ODFI’s are responsible for all entries originated through the ACH Network using the ODFI’s routing number and that ODFI’s are responsible for their ACH clients' compliance with the Nacha Rules. In addition, because the payments industry is constantly evolving, ODFI’s need to keep their ACH clients informed of Nacha Rule changes. Therefore, ODFI’s should have a formalized process to keep their ACH clients informed of Nacha Rules and originator responsibilities.

The Nacha Rules do not prescribe a specific methodology for ODFIs to do this. It is up to the ODFI to determine the best process for keeping its ACH clients informed. The following are just a few examples of ways ODFI’s can accomplish this:

Purchase and provide ACH clients with the Nacha Operating Rules and Guidelines book
Purchase and provide ACH clients with the eBook version of the Nacha Operating Rules & Guidelines via an App
Purchase and provide ACH clients with a Premium Subscription Code to gain online access to the Nacha Operating Rules & Guidelines by registering as a Premium User
Purchase and provide ACH clients with handbooks specific to the Standard Entry Class (SEC) type code(s) they originate
Provide ACH clients with free online access to the Nacha Operating Rules by instructing them how to register as a Basic User at www.NachaOperatingRulesOnline.org. Basic user access provides free “read-only” rights to view the Nacha Operating Rules online
Create and provide ACH clients with training materials that include pertinent information regarding Nacha Rules, Rule changes and ACH originator responsibilities

Questions?

Keeping your ACH clients informed is critical. If you have any questions or need assistance guidance for doing this, 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.