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Unlocking the Power of ACH Compliance Reviews: Requirements and Benefits for Third-Party Senders and Service Providers


The Automated Clearing House (ACH) system has become integral to electronic payments in today's fast-paced payment environment. With the increasing reliance on ACH transactions, both Third-Party Senders and Third-Party Service Providers play crucial roles in facilitating secure and efficient payment processing. These entities must undergo regular ACH Compliance Reviews annually to ensure compliance, mitigate risks, and maintain trust by December 31st. Let us explore the requirements and benefits of ACH Compliance Reviews for Third-Party Senders and Service Providers, along with examples of their roles in the financial ecosystem.

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Safeguarding Against ACH Fraud: Ten Essential Steps for Financial Institutions and Businesses


As the need for faster payments increases, financial institutions and businesses face an ever-growing threat of cybersecurity risks and ACH (Automated Clearing House) fraud. ACH fraud can have devastating consequences, including substantial financial losses and irreparable damage to a company's reputation. Financial institutions and businesses must take proactive measures to mitigate the risk of ACH fraud. This article outlines ten essential steps that can help protect financial institutions and businesses from falling victim to ACH fraud and provides additional information surrounding the topic.

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ICYMI: An Important Reminder About the CRA Public File, and More


As many of you are still digesting the CRA Modernization final rule that was published in the Federal Register February 1 of this year, it is important not to take for granted that many of the mandatory compliance dates are not effective until January 1, 2026.  It is also more dangerous than not to expect that the recent filing from various trade groups challenging the legality of the rule itself will simply make this all go away.  The effective date of the final rule is April 1, 2024, and you need to be ready for certain provisions that will become mandatory on this day.  Two provisions require immediate action, one of which applies to all banks, regardless of size. 

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Understanding ACH Risk Assessments: A Crucial Requirement of the Nacha Rules


The Automated Clearing House (ACH) network has revolutionized how financial transactions are processed in today's digital age. With the increasing reliance on ACH payments, ensuring the security and integrity of these transactions becomes essential. The National Automated Clearing House Association (Nacha) has established rules and guidelines to govern the ACH network, including ACH risk assessment requirements. Let us explore the significance of ACH risk assessments and how they contribute to maintaining a safe and efficient payment ecosystem.

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Nacha's Updated Written Statement of Unauthorized Debit: Should You Update Your WSUD Forms?


Consumer fraud has become a growing concern, particularly concerning financial transactions and investments. In light of recent fraud trends, including high-profile cryptocurrency fraud cases,  Nacha has recognized the need to address the risks associated with false claims of unauthorized ACH debits. To protect consumers and educate them about the potential consequences of making such claims, Nacha has updated its sample Written Statement of Unauthorized Debit (WSUD) to include language outlining the penalties for misrepresentation.


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Saltmarsh Hosts 18th Annual BankTalkCommunity Bank Training & Network Events


Our 18th annual community bank event, BankTalk, in Tampa, brought together over 100 community bankers and subject matter experts to discuss the challenges facing the industry and also opportunities from technology and innovation to shape the future of the industry. This year's BankTalk is something to rave about, and if you missed out, don't worry – we're here to take you on an exclusive journey through the highlights! 

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Jay Newsome Joins Financial Institution Consulting Group & Expands Firm's Alabama Market Presence


Join us in welcoming Jay Newsome, CPA, to the Saltmarsh Family! With over 20 years of experience and recognition as one of Business Alabama Magazine's 2022 Faces of Finance, Newsome brings exceptional knowledge and expertise to Saltmarsh's team of talented accountants and consultants dedicated to advising financial institutions of varying sizes and complexity. 

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Best Practice Ideas from the Asset-Liability Management Trenches


Recent industry uncertainties have highlighted the need to further question and research your Asset Liability Management (ALM) practices especially related to modeling Interest Rate Risk (IRR) and Liquidity.

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Managing Risk: Fraud Deterrence Is Always a Priority


As we inch closer to marking a quarter of the way through the 21st century, one thing has become very apparent: the 21st century is anything but stable. In 22 years, the world and its economies have endured the threat of international terrorism, a global banking crisis, a worldwide health pandemic, high inflation here in the US, and overseas, the largest European conflict since World War II. Each incident presented unique challenges to consumers and businesses alike, but one thing remained constant: fraud.

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Webinar on Demand: Getting to Know FedNow, Now


The Financial Institutions practice group at Saltmarsh brings you The Payments Professor to discuss operational and other issues financial institutions should know for FedNOW implementation. Access the webinar on demand!

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Nacha's 2023 Rules Updates: Are You Affected?


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.

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Do I Need an ACH Audit?


We often get the question. “Do I need an ACH audit?” The general requirement per the Nacha Operating Rules is that a bank or credit union (DFI) must conduct, or have conducted, an audit of its compliance with these Rules annually. However, other parties involved in processing ACH transactions need an ACH audit, too.

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Webinar Recording: Top 8 ACH Audit Findings You Should Be Aware Of


In this webinar, Senior Financial Institutions Consultant, Sallie O’Brien, AAP, APRP, will discuss today’s top audit findings and best practices to stay in compliance with Nacha Operating Rules for financial institutions. Access webinar materials here!

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Think CECL Is Only for Banks? Not So Fast!


As we’ve previously noted, most of the CECL-related focus has been on loans receivable, and to a lesser extent, debt securities. Are there any other financial assets that fall under the CECL guidance? The answer might surprise you.

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Saltmarsh Hosts 17th Annual Community BankTalk Event


For the past 17 years, the Saltmarsh Bank Advisors have brought hundreds of financial institution professionals together for community banking events, BankTalk, to learn about advancements in the industry, regulatory updates and much more. With the turn to virtual after 2020, the team hosted the last three annual events virtually – but that didn’t stop them from getting an insightful lineup of speakers and content!

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Preparing for $500 Million in Assets


Is your bank approaching $500 million in assets? Have you already crossed that threshold recently? As your bank continues to grow, your reporting needs may change due to FDICIA regulations. Saltmarsh is here to help ensure you remain compliant and that your bank has the resources, time and expertise to meet regulatory requirements.

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Secure Exchange of Standardized Letters of IndemnityNow in Nacha's Risk Management Portal


Many financial institutions require a written indemnification agreement to be completed in connection with requested ACH returns. This is especially the case when the return of funds cannot be completed using an ACH return entry (i.e., an R06 Return Reason Code) or funds are returned outside the ACH Network (i.e., via wire or check). 

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Best Practice Suggestions for Back-Testing Asset-Liability Management (ALM) Models for Accuracy


Back-testing has been challenging during this COVID period due to large volume variances and asset yield variances caused by high loan and deposit growth coupled with forecasts not incorporating PPP loan-related fees.

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Words to Live By


When I was asked to repurpose a blog I wrote almost 10 years ago, at first, I thought it would be hypocritical of me. I had written four recommendations to help my business clients achieve peace and strength during a time of unprecedented change, and unfortunately, I had not been practicing my own recommended behaviors, despite being bombarded with changes! 

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Webinar Materials: The New ACH Rules on Micro-Entries


In this webinar, Financial Institutions Senior Consultant Janice Weisz, AAP, will provide a high-level overview of upcoming rules associated with Micro-Entries.

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Nacha Micro Entry-Rule


Micro-Entries are a generally accepted method in the marketplace for an ACH originator to test the validity of a receiver’s account. Although originators have used this low-cost option for quite some time, Micro-Entries are not defined within the Nacha Operating Rules.

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Elder Financial Exploitation by the Numbers


For those of you working diligently in the financial industry, we remind you that June is Elder Financial Abuse month. Elder financial exploitation (EFE), a form of Elder Abuse, is the most common form of elder abuse. EFE is defined as the illegal or improper use of an elderly adult's funds, property or resources by another individual. Sadly, this exploitation is alive and well all year round.

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CECL: What About Credit Losses on Debt Securities?


Since the initial roll-out of ASU 2016-13, Financial Instruments—Credit Losses (Topic 326), much of the prevailing focus has been on accounting for expected credit losses in loan portfolios. As the CECL implementation date draws near for nonpublic business entities, we are starting to receive new questions about CECL’s impacts to securities portfolios as well.

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Supplementing Data Security Requirements Rule Phase 2Effective June 30, 2022


Nacha’s Supplementing Data Security Requirements rule expands the existing ACH Security Framework to explicitly require large, non-financial institution Originators, Third-Party Service Providers and Third-Party Senders to protect account numbers (consumer and non-consumer) used in the initiation of ACH entries by rendering them unreadable when stored electronically.

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Webinar Materials: ODFIs - How Do You Keep Your ACH Clients Informed?


Keeping your ACH clients informed is critical. In this webinar Senior Consultant Janice Weisz, AAP, will discuss the importance of educating ACH clients and will share tools and best practices to keep ACH clients informed of Nacha Rules and originator responsibilities.

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