Nacha Micro Entry-Rule

7/12/2022 - By Allie Jackson

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.

Changes are coming to ACH Network participants that use Micro-Entries due to a new, two-phase Nacha Operating Rule. The purpose of the Micro-Entries Rule is to improve the effectiveness of Micro-Entries as a means of account validation, to better enable Financial Institutions and other parties to identify and monitor Micro-Entries, and to improve the quality of Micro-Entries in the ACH Network.

Specifically, the Micro-Entry Rule will:

  1. Define Micro-Entries within the Nacha Operating Rules
  2. Standardize formatting elements for Micro-Entries
  3. Establish other Micro-Entry origination practices
  4. Apply risk management requirements to the origination of Micro-Entries

1. Micro-Entry Defined

  • A Micro-Entry is a type of ACH entry that is a credit or debit entry used by an originator for the purpose of verifying a receiver’s account or an individual's access to an account.
  • A credit Micro-Entry must be in the amount of less than $1.00.
  • One or more debit Micro-Entries must not exceed, in total, the amount of the corresponding credit Micro-Entries.
  • This definition accommodates the existing practices of offsetting the amounts of credit Micro-Entries with one or more debits, which nets the total verification practice to $0 and permits a debit offset to be greater than $1.00 only to offset the amounts of credit Micro-Entries.

2. Micro-Entry Standardize Formatting Requirements

  • "ACCTVERIFY” must be inputted in the Company Entry Description field.
  • The Company Name must be readily recognizable to the receiver and be the same or similar to the Company Name that will be used in future entries.

3. Micro-Entry Origination Practices

  • An originator that is using debit Micro-Entry offsets must send the debits and the corresponding credit Micro-Entries simultaneously for settlement at the same time.
  • The total amount of the credit Micro-Entry or Entries must equal to or greater than the value of the debit Micro-Entry or Entries.
  • Originators of Micro-Entries may initiate future entries to the receiver’s account as soon as the originator’s process for validating the amounts of the Micro-Entries has been completed.  The originator cannot originate a future entry simultaneously with Micro-Entries.

4. Origination of Micro-Entries Risk Management Requirements

  • Originators of Micro-Entries must conduct commercially reasonable fraud detection on its use of Micro-Entries, including by monitoring of forward and return volumes of Micro-Entries. Monitoring forward and return volumes, at a minimum, will establish a baseline of normal activity for the originator. Using commercially reasonable fraud detections will minimize the incidence of fraud schemes that make use of Micro-Entries.

Impact to Participants

Originators 

Originators that use Micro-Entries will have to adopt new formatting conventions by including “ACCTVERIFY” in the Company Entry Description and meeting the Company Name requirement for these entries. Originators will have to adhere to the required timing and waiting periods associated with Micro-Entries. Originators that do not already have in place commercially reasonable fraud protection for their Micro-Entry origination will have to begin monitoring their forward and return volumes. They may also consider practicing other desired velocity checks or anomaly detection.

ODFIs

ODFIs will need to make sure that their originators that use micro-entries are aware of the Rule and its requirements.

RDFIs

RDFIs should consider incorporating Micro-Entry activity into existing fraud detection, AML and money mule detection processes. To advance the effectiveness of Micro-Entries as a fraud mitigation tool, RDFIs should consider treating corresponding credit and debit Micro-Entries the same when making post/no post decisions, i.e., they should either post both or return both. RDFIs that have not automated their return processing are encouraged to do so to minimize the impact that additional administrative returns may have on their operations.

Effective Date

The Micro-Entry rule will become effective in two phases.

Phase 1 Effective September 16, 2022

  • Micro-Entries will be defined as ACH credits of less than $1.00, and any offsetting debits, for account validation. Credit amounts must be equal to, or greater than, debit amounts and must be transmitted to settle at the same time.
  • Originators must use “ACCTVERIFY” in the company entry description field.
  • Company name must be easily recognizable to receivers and the same or similar to what will be used in subsequent entries.

Phase 2 Effective March 17, 2023

  • Originators must use commercially reasonable fraud detection practices. This includes monitoring forward and return Micro-Entry volumes.

Staying in compliance can be challenging, if you have any questions or need assistance preparing for the new Nacha Rules, 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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