{"id":696,"date":"2024-06-20T14:52:10","date_gmt":"2024-06-20T14:52:10","guid":{"rendered":"https:\/\/rembrandtai.com\/?p=696"},"modified":"2024-06-20T14:52:10","modified_gmt":"2024-06-20T14:52:10","slug":"preparing-for-the-nacha-operating-rule-changes","status":"publish","type":"post","link":"https:\/\/rembrandtai.com\/news\/preparing-for-the-nacha-operating-rule-changes\/","title":{"rendered":"Preparing for the Nacha Operating Rule Changes"},"content":{"rendered":"

Disclaimer: This is for educational purposes only and does not provide a legal or official interpretation of the Nacha Operating Rules and Guidelines. Opinions are that of the author only.<\/em><\/p>\n

Nanci McKenzie, JM, AAP, APRP<\/a> Independent Consultant June 2024<\/p>\n

The National Automated Clearing House (Nacha) has overseen the health and integrity of the most popular electronic payment, the ACH network, since 1974. Over the years, the ACH Network has grown to over 31 billion transactions equaling just over $80 trillion in 2023. With that kind of volume, it is understandable that adjusting for the changes in economy, technology, and the greed from fraudsters to steal money electronically has become a huge challenge for the ACH Network. Financial institutions are placed in the best position with monitoring and identifying electronic transactions. But trying to determine transactions which are legitimate and authorized and those which are not, especially when they are credits, has become a topic of concern which most, including myself, never thought we would be tackling! Who would question a credit coming into an account? Wouldn\u2019t we all welcome extra money in our account(s)?<\/p>\n

Nacha responded to the increase in credit push fraud the United States saw with stimulus payments, unemployment benefits, and Paycheck Protection Program (PPP) loans that we saw throughout the COVID-19 pandemic by announcing the \u201cA New Risk Management Framework for the Era of Credit-Push Fraud\u201d2 in September 2022. Along with the need for a revised risk management framework to include credit transactions, Nacha recognized the need for changes to the Operating Rules to help reduce and prevent the continued abuse of credit transactions financial crimes such as money laundering, account takeovers, romance scams, and the plethora of other fraudulent activity by sending a request for comment back in May of 2023 and approving revisions and new rules for ACH transactions within the financial industry.<\/p>\n

Monitoring transactions has been an important part of risk management, anti-money laundering (AML) and fraud prevention programs for many years. Screening senders and receivers of electronic transactions for OFAC compliance and AML suspicions have been a part of financial institutions daily practices but buckle up! Monitoring transactions will require a much more robust flavor and includes all participants of an ACH entry except for the consumer or the \u201cReceiver\u201d.<\/p>\n

I identify and summarize some<\/u> of the changes and effective dates but want to stress the importance of enhanced monitoring responsibilities for financial institutions, non-financial institutions, and originators within their established risk management program(s) <\/em>Now is the time to prepare for these changes because this is not something that is in practice today for much of the financial industry. <\/strong>For full details of the new and revised rules visit Nacha Operating Rules – New Rules | Nacha<\/a> and access the complimentary webinar recording.<\/p>\n

Effective March 20, 2026<\/u><\/strong><\/p>\n

Fraud monitoring will be required by:<\/p>\n