Nacha has created an Opt-In Program to better facilitate the return and recovery of potentially fraudulent unemployment benefits originally paid by ACH credits (i.e., Direct Deposit). ODFIs for state unemployment benefit agencies are able to “opt-in” on behalf of those agencies.
What’s In It For You?
Numerous financial institutions, as well as their state agency customers, leverage Nacha Operating Rules and formats to recover questionable unemployment benefits that were originally paid via ACH credits. The effort aims to improve government and financial institution operations and processing, and to recover funds that may not have been disbursed to appropriate parties.
- A Participating RDFI can send funds back to a state unemployment agency via a “Program Return” for less than the amount of the original ACH credit (partial amount); or also for the full amount of the original entry.
- Program Returns are treated as an ODFI Request for Return under the Nacha Rules, in which the ODFI indemnifies the RDFI for the return of funds.
- A Program Return may be sent using a new CCD format specified by the opt-in rules. A Participating RDFI may also send the full amount of the original ACH credit via an R06 return, if the Participating ODFI has indicated acceptance.
- Program Returns (CCD and R06), in accordance with Program Rules, may be sent for two years after the settlement date of the original ACH credit.
Instructions for Participants
Participating RDFI Instructions
Participating RDFIs do not need to sign and submit a Program Agreement. RDFIs are not required to sign participant agreements, but by sending Program Returns are agreeing to abide by the Opt-In Program Rules.
- Participating RDFIs must obtain the following information from this program page:
- If the desired state is listed as participating on the simple roster, the Participating RDFI must log into Nacha’s Risk Management Portal to view the full roster information for the Participating State and ODFI
- Program Returns must be sent from the Participating RDFI using the specified format in Appendix One of the Program Agreement, in accordance with the full roster specifications and Program Rules
- Participating RDFIs should be aware that some ODFIs may accept funds from entries originated through other FIs or may not accept R06 returns, dictating conditions for the CCD Program return
- Other eligibility conditions may exist as detailed in the full roster
Participating ODFI Instructions
Interested ODFIs should work with Nacha staff to complete the on-boarding process and obtain detailed instructions for completing the Opt-In Program Agreement.
- Direct inquiry on participation to Amy Morris at firstname.lastname@example.org or NachaNetworkRules@nacha.org
- A Participating ODFI must complete the Opt-In Program Agreement, designating for which state(s) and how they will accept Program Returns. Program Returns may be accepted as the following:
- Full amounts
- CCD standardized format as found in the Program Rules; and/or
- R06 Return
- Partial amounts
- CCD standardized format as found in the Program Rules
- Other conditions that the ODFI may consider are:
- If any Company ID restrictions exist
- Whether or not the ODFI will accept:
- Funds without an account number
- Routing information must be provided
- Funds originally sent through another ODFI
- Full amounts
- Submissions of a Program Agreement with draft or completed information must be sent via secure means, as per on-boarding discussions.
- Provide Participating States with instructions/reporting to identify received Program Returns, as determined by ODFI.
The simple roster contains the current list of participating states and corresponding ODFIs. A Participating RDFI may initiate a Program Return for a questionable unemployment benefit credit entry under this program to any Participating State/ODFI.
ODFIs for state unemployment agencies must opt-in to the program on behalf of the state agencies. ODFIs considering participation in this program should contact Amy Morris at email@example.com or NachaNetworkRules@nacha.org
RDFIs are not required to sign participant agreements; but by sending Program Returns are agreeing to abide by the Opt-In Program rules.
Participating RDFIs must send Program Returns in accordance with the instructions provided by the ODFI in the full roster (available in the Nacha Risk Management Portal)
If you have questions about the program, or would like to participate, let us know.