ACH Rules Enforcement Panel

Role and Operation: This panel falls under the National System of Fines and is the final authority regarding the imposition of fines when there is a violation of the Nacha Operating Rules. Panel members make decisions in accordance with Appendix Nine (Rules Enforcement) of the Rules. Members participate in monthly conference calls. 
 
Composition: The panel is comprised of a primary and alternate representative from each of the following industry participants:

• The Federal Reserve Bank
• A private-sector ACH Operator
• A large asset size commercial bank or savings institution (greater than $100 billion)
• A medium asset size commercial bank or savings institution ($5 billion to $100 billion)
• A small asset size commercial bank or savings institution (less than $5 billion)
• A credit union
• A Payments Association

 
At this time, Nacha is soliciting nominations for: 

• A small asset size commercial bank or savings institution (less than $5 billion)
• A credit union

Participant Expectations: The ACH Rules Enforcement Panel requires a high level of participation due to the nature of the work. Five of the seven panel members or alternates must be present on a conference call to constitute a quorum in order for the Panel to conduct business. In addition to participation in monthly conference calls, panel members must have a thorough knowledge and understanding of the ACH Network and Rules. Preference will be given to nominees that meet one or more of the following criteria: 

1. Accredited ACH Professional
2. Minimum of three years ACH payments experience
3. Previous participation on Nacha Rules & Operations Committee, Nacha Standing Committee, Rules Work Group, Nacha’s Board of Directors, or an individual serving in an official capacity for a Payments Association

Nacha Arbitration Board

Role and Operation: The Arbitration Board governs the settlement of disputes arising under the Nacha Operating Rules between Participating DFIs. From one to three arbitrators, depending on the amount of the damages, are selected to hear an arbitration case. Arbitrator(s) review all the materials presented and decide a case in accordance with the Rules. Members of the Arbitration Board will also serve on the Appeals Panel. Up to three arbitrators will serve on the Panel, acting as an appellate body for enforcement cases involving suspension from use of the Network.

Composition: The Arbitration Board consists of professionals from banking and banking-related industries. The Arbitration Board is comprised of volunteer members who serve a three-year term. Volunteers for the Board are chosen by the Nacha Board from the volunteer submissions prior to the end of the existing term.

Participant Expectations: Arbitrators are chosen to hear an arbitration case on a rotational basis. Arbitration Board members must have a thorough knowledge and understanding of the ACH Network and Rules. Preference will be given to nominees that meet the following criteria:

1) Accredited ACH Professionals,
2) attorneys with experience in electronic payments processing,
3) minimum of three years ACH payments experience,
4) previous participation on the Rules & Operations Committee, Board of Directors, or an individual serving in an official capacity for a Payments Association. 

Term: The Arbitration Board has a three year term. The current term started on January 1, 2024 and ends on December 31, 2026. The Board of Directors approves appointments to the Nacha Arbitration Board.

Risk Management Advisory Group (RMAG)

Role & Operation: The Risk Management Advisory Group serves in an advisory capacity to Nacha's executive management and Board of Directors on risk management related topics to ensure ongoing strength, stability and continued ACH Network quality. The Group works with Nacha staff and key industry stakeholders to produce sound business practices, business cases for rules proposals, Board Policy Statements, tools, white papers and other communications, and collaborates and coordinates with payments professionals across payments channels.

Composition: The Group is comprised of representatives from financial institutions, Payments Associations and ACH Operators. The Group includes from 15 to 20 participants including the Chairperson. The chair of Nacha’s Board of Directors appoints the chair of the Risk Management  Advisory Group, who then selects group members from the nominations received.

Participant Expectations: Group members are expected to participate on monthly conference calls, attend two in-person meetings per year, and participate in at least one work group and/or related efforts. A participant who misses three calls or meetings will have their participation reevaluated. 

Term: The Risk Management Advisory Group has a two-year term. The current term started on January 1, 2024 and ends on December 31, 2025. 

Nacha Staff Contacts

For more information on these opportunities, please contact:

Arbitration Board and ACH Risk Enforcement Panel
Lorie Nash, AAP
Senior Director, Compliance
703-561-3917
Nacha-Network-Rules@Nacha.org

Risk Management Advisory Group (RMAG)
Jordan Bennett
Senior Director, Network Risk Management
703-561-3968
Nacha-Network-Rules@Nacha.org