Direct Access Registration Requirements

NACHA’s Board of Directors approved a Policy Statement on Direct Access on July 30, 2008. This policy addresses the importance of financial institutions registering their direct access relationships with NACHA and following prudent risk management techniques including adherence to best practices, for the duration of these relationships.

The Board of Directors expects that financial institutions will register their direct access relationships with NACHA in order to better quantify the number of, and the risk profile for, direct access relationships.  Compliance with this policy will not be enforced as a rule until NACHA has adopted a rule amendment regarding registration of direct access relationships.  NACHA will work with the ACH Operators to validate that financial institutions have registered all direct access relationships.

NACHA established this secure website for financial institutions to register direct access relationships or acknowledge a statement that they do not maintain any direct access relationships for ACH debit transactions. This site includes the forms to complete the registration process and a link to the Board of Director’s policy statement.  

Direct Access Defined

Registration is solely focused on direct access relationships involving the origination of ACH debit transactions.  If your institution has a direct access relationship involving ACH credit transactions, your organization is not being asked to register those relationships.

For purposes of registration, direct access includes the following:

(1) Originators that transmit ACH files [transactions] directly to an ACH Operator using a financial institution’s routing and transit number and settlement account; or

(2) Third Parties (either a financial institution’s Third Party Service Provider or an Originator’s Third Party Sender) that transmit ACH files [transactions] directly to an ACH Operator using a financial institution’s routing and transit number and settlement account.

For purposes of registration, direct access excludes:

(1) Financial institutions that transmit files using another financial institution’s routing number or settlement account (correspondent/respondent relationships); and

(2) Third Parties that transmit ACH files solely on behalf of the financial institution and do not have direct agreements with Originators (and are not themselves Originators).

Registration Overview

The links for financial institutions to complete their registration are below under “Direct Access Registration Forms.” 

Financial institutions that do not maintain any direct access relationships for ACH debit transactions should complete “Form A” below acknowledging a statement to this effect.

Financial institutions that have direct access relationships for ACH debit transactions should complete “Form B” for each direct access relationship.  Financial institutions with direct access relationships should return to this website to complete “Form C” on a quarterly basis to report volume data on the direct access entity, and complete “Form D” when there is a significant change in the relationship with the direct access entity, such as new contact information for the Third Party or Originator or if the relationship is terminated.

Direct Access Registration Forms

Form A:  Financial Institution Statement That It Does Not Maintain Any Direct Access Relationships

Form B: Financial Institution Registration of Direct Access Relationships

Form C: Financial Institution Reporting of Quarterly Data

Form D:  Financial Institutions Update of Existing Registration Data

Direct Access Information

NACHA Board of Directors’ Policy Statement on Direct Access

NACHA Contacts for Direct Access Registration

NACHA Risk Management at (703) 561-1100
Jeanette A. Fox, AAP, jfox@nacha.org
Deborah Shaw, AAP, CTP, dshaw@nacha.org
Cathy McNickle, cmcnickle@nacha.org