Rules & Operations Alerts

Rapid change in the payments industry means evolving rules and regulations governing the payments channels. Here are some of the recent changes that may apply to your industry.

Nacha Rules Updates and Supplements

The Nacha Operating Rules define the obligations and responsibilities of each participant.  The following is not an exhaustive list of all Rule updates but key changes that have a higher impact on Originators and Third-Party Senders.

 Rule Update Key Elements  Effective Date(s) 

Supplement #2-2019- Differentiating Unauthorized Returns

The rule re-purposes an existing little-used Return Reason Code (R11) that will be used when a receiving customer claims that there was an error with an otherwise authorized payment. Currently, Return Reason Code R10 is used as a catch-all for various types of underlying unauthorized Return reasons, including some for which a valid authorization exists, such as a debit on the wrong date or for the wrong amount.  Financial Institutions, Originators, and Third-Party Senders would have a clearer information in instances in which a customer alleges an error as opposed to “not authorized.”

Phase 1 – April 1, 2020
Phase 2 – April 1, 2021

Supplement #1-2019-ACH Rules Compliance Audit Requirements

This Rule changes the structure of the audit requirement within the Rules but does not change the requirement to conduct a Rules compliance audit annually. Participants that have relied exclusively on Appendix Eight as a checklist for conducting their audits should be aware of its limitations and should be prepared to audit on all relevant rules, even those not currently expressly listed within former Appendix Eight language.
January 1, 2019
ACH Operations Bulletin #4-2019: Extension of the Effective Date for Rule Supplementing Fraud Detection Standards for WEB Debits
In November 2018, the Nacha membership approved a set of rule changes related to ACH quality and risk management. Included as part of these rules changes was a supplement to the existing rule on fraud screening for WEB debits. The upcoming effective date of the rule on Supplementing Fraud Detection Standards for WEB Debits is extended from January 1, 2020 to March 19, 2021. March,19 2021
Supplement #2-2018 ACH Quality and Risk Management Topics

Originators, Third-Party Senders, and Third-Party Service Providers are encouraged to review this Rule for impact to their operating environment. This Rule focuses on the following topics:

  • Return of Questionable Transaction 

  • Supplementing Fraud Detection Standards for WEB Debit Entries

  • Supplementing Data Security Requirements

June 21, 2019

January 1, 2020

Phase One - June 30, 2020
Phase Two - June 30, 2020

ACH Network Risk and Enforcement Topics This Rule outlines the changes to the return threshold percentages and adds clarification to the Reinitiation of Entries.
September 18, 2015
Supplement #2-2016

Both Originators and Third-Party Senders may need to review the ACH Formatting requirements outlined in the Minor Rules Topic. Third-Party Senders should review the Third-Party Sender Registration Rule and understand their ACH Compliance requirements.

  • Third-Party Sender Registration

  • Minor Rules Topics

  • Network Administration

September 29, 2017

August 18, 2016
September 3, 2016 
March 16, 2018

January 1, 2017
ACH Operations Bulletin #2-2014: ACH Transactions Involving Third-Party Senders and Other Payments Intermediaries

This ACH Operations Bulletin is intended to provide some representative examples that should help participants and observers properly categorize the roles of the parties in payment scenarios involving different types of third-party payment intermediaries and understand how ACH transactions should be identified for consumers.

March 21, 2014