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Updates to NACHA Rules

Effective March 18, 2022

The Same Day ACH Dollar Limit will increase from $100,000 to $1,000,000 per payment.

Effective March 19, 2021

Expanded Access to Same Day ACH-Creates a third Same Day ACH processing window that expands ACH by two hours. This allows Same Day ACH transactions to be submitted to the ACH Network for an additional two hours until 4:45 p.m. ET providing great access for our customers.

Effective June 30, 2021/2022

Data Security Rule- Supplementing Data Security Requirements are extended by one year, to June 30, 2021 and June 30, 2022.

  • Phase 1 of the Rule, which applies to ACH Originators and Third-Parties with more than 6 million ACH payments annually, is now effective on June 30, 2021.
  • Phase 2 of the Rule, which applies to ACH Originators and Third-Parties with more than 2 million ACH payments annually, is now effective on June 30, 2022.

Under the Rule, Financial Institutions, Originators, Third Party Service Providers and Third Party Senders are required to establish, implement and update, as appropriate, security policies, procedures and systems related to initiation, processing and storage of ACH transactions. The new rule supplements the existing rules by requiring ACH Originators and Third Parties to protect account information used in ACH payments by rendering it unreadable when stored electronically. Covered parties are urged to become compliant with the new Rule as soon as circumstances permit, but no later than these new effective dates.

Notice for Reinitiating ACH Returns

It is your responsibility to comply with NACHA Operating Rules & Guidelines when reinitiating a returned ACH origination.

An ACH entry that has been returned may be reinitiated if:

  • The entry has been returned for insufficient or uncollected funds (cannot be reinitiated more than two times after return of original entry); or
  • The entry has been returned for stop payment and reinitiation has been authorized by the Receiver; or
  • The Originator has remedied the reason for the return.

For full details regarding ACH Originator responsibilities you can access your subscription with NACHA at http://www.achrulesonline.org

COVID-Related Relief from Certain Nacha Operating Rule Provisions Will Expire on October 1, 2022

Summary

Beginning in March 2020, Nacha provided relief from certain provisions of the Nacha Operating Rules due to impacts of the Coronavirus pandemic. In consultation with its Rules and Operations Committee and its Risk Management Advisory Group, Nacha has determined that these various reliefs now can be allowed to expire. As the relief generally took the form of non-enforcement, ACH participations can consider these Rule requirements to be enforceable again beginning after the expiration date of October 1, 2022.

Expiration of Relief

  • The requirements for the delivery of a Record of Authorization, a Source Document/Item, and a Written Statement of Unauthorized Debit will return to the 10 banking-day timeframe. This will apply to requests for these documents made on or after Monday, October 3, 2022
  • Required response times within Nacha’s Rules enforcement process will return to 10 banking days. This will apply to responses that are required for enforcement letters or other communications received on or after Monday, October 3, 2022.
  • Written Statements of Unauthorized Debits will return to having a signature or similar authentication requirement. (Note that the Nacha Rules allow for the electronic signature of a WSUD, and that a rule became effective in September 2021 that codified and encouraged RDFIs to provide for electronic signatures of WSUDs.)
  • The authorization of POP Entries will again require a signature.
  • The authorization of POS Entries will again have a signed or similarly authenticated requirement when Originators elect not to ask customers to enter a PIN.
  • Nacha will not automatically provide enforcement relief for elevated return rates and levels due to pandemic impacts. ODFIs will still be able to address factors contributing to elevated levels of administrative or overall returns in their responses to enforcement proceedings.

Effective Dates

Nacha affirms the effective dates of all newly adopted Rules. Of the rules for which additional grace periods were provided in 2020, all such periods have elapsed except for Phase 2 of the Supplemental ACH Data Security rule, which applies the new data security requirements to Originators and Third-Party Senders with ACH volume of two million or more transactions annually. The additional non-enforcement grace period continues through June 30, 2023 for those Originators and Third-Parties working in good faith to implement the rule.

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