Nacha News

Nacha creates broadly adopted payment and financial messaging rules and standards through consensus-led governance, international collaboration, and innovative development practices. We continually advance the ubiquitous ACH Network and engage diverse stakeholders to accelerate a digital future of global financial services interoperability.

Sign up for Press Releases Sign up for Blog Posts

Featured News

The American Economy Runs on ACH, Says Mercator Advisory Group White Paper

HERNDON, Va., May 28, 2020 – The ACH Network is woven into the daily payment activity of American consumers, businesses and government, says a Mercator Advisory Group white paper published today titled, “The Expanding Role of ACH in the Era of Faster Payments.” The paper also highlights how – as payments become faster – ACH supports the future of the industry with Same Day ACH, while providing the money-movement infrastructure for many other payment products.

Nacha Reports ACH Network Growth of 7.1% in First Quarter 2020; Expects Slowdown Due to COVID-19

HERNDON, Va., April 9, 2020 – The ACH Network opened 2020 with a strong first quarter, as the number of payments rose 7.1% from a year earlier. The results were driven primarily through robust growth occurring prior to the slowdown of economic activity due to COVID-19.

“While ACH results for the entire first quarter are positive, the current coronavirus national emergency is already impacting payment system volumes, including the ACH,” said Jane Larimer, Nacha President and CEO. 

ACH Operations Bulletin #1-2013: ODFI Warranty for Outbound IAT Entries

This ACH Operations Bulletin advises Originating Depository Financial Institutions (ODFIs) and other ACH participants of an amendment to the Nacha Operating Rules regarding the warranty an ODFI makes for an Outbound IAT Entry. This Bulletin is being issued due to the immediacy of the effective date of the Rules amendment.

Currently, the Rules provide that the ODFI of an Outbound IAT Entry warrants to the RDFI, ACH Operator and Gateway that the IAT Entry complies with the laws and payment systems rules of the receiving country. In practice, the breadth of this warranty has been identified by financial institutions as a barrier to the Origination of IAT Entries. The Rules amendment narrows the scope of this warranty to focus solely on the authorization of the Entry, when authorization is required by the laws or payment system rules of the receiving country. This change is intended to encourage additional origination of Outbound IATs by focusing the warranty on the more limited subject matter most critical to the permissibility of the Entry.

Previously under the Rules, the ODFI’s warranty for Outbound IAT Entries was broad and required the ODFI to warrant that the Entry complies with all laws and payment system rules of the foreign (receiving) country. In practice, however, this warranty has been a barrier for many ODFIs to originate Outbound IATs. Given the industry’s investment in enabling IAT Entries, and given other impending regulatory requirements regarding international remittances, Nacha and the industry are interested in lowering barriers to the use of IAT.

Under the revised Rules, ODFIs transmitting Outbound IAT Entries now warrant only that they are in compliance with foreign laws or payment system rules regarding authorization of the Entry, if authorization is required. ODFIs presumably will pass this warranty to their Originators in order to confirm that Originators have obtained any authorization required for their Outbound IATs.

Notwithstanding this narrowing of the warranty by ODFIs, Gateways should not have to bear the risk that foreign law or payment system rules may prohibit the processing of a transaction, possibly resulting in the seizure of funds. Accordingly, the Rules also now specifically allocate to the Originator of an Outbound IAT Entry (credit or debit) the risk that foreign law or payment system rules may prohibit the processing of that transaction. Under the revised rules, the risk is borne by the ODFI as between the ODFI and the Gateway, and by the Originator as between the Originator and the ODFI. Any loss therefore would ultimately accrue to the Originator unless there is an agreement between the Originator and the ODFI, or between the ODFI and the Gateway, to allocate the risk of loss differently (or a different result is required by applicable law or regulation). It is incumbent upon Originators to understand the nature of sending payments to or seeking payments from other countries and the potential risk that international payments processing entails.

These changes to the Nacha Operating Rules regarding the ODFI’s warranty with respect to Outbound IAT Entries are effective on March 15, 2013. Rules sections impacted by these changes appear below and reflect updated language:

  • Article Two – Rights and Responsibilities of ODFIs, Their Originators, and Third-Party Senders
  • ​Subsection Additional ODFI Warranties for Outbound IAT Entries
  • In addition to the other warranties contained within these Rules, an ODFI initiating an Outbound IAT Entry warrants to each RDFI, ACH Operator, and Gateway:
    • Compliance with U.S. Legal Requirements. The Originator and ODFI are in compliance with U.S. Legal Requirements with respect to the IAT Entry, including their obligations under programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN).
    • Compliance with Foreign Laws or Payment System Rules Regarding Authorization. If the laws or payment system rules of the receiving country require authorization with respect to an IAT Entry, the ODFI warrants that the authorization of the IAT Entry complies with the laws and payment system rules of the receiving country.
  • Subsection Assumption of Risk (new subsection)

    As between the ODFI and the Gateway of an Outbound IAT Entry, the ODFI bears the risk that the laws of the receiving country prohibit or otherwise preclude the processing, settlement, or transfer of the proceeds of the Entry, including through blocking or other sequestration or seizure of funds, unless otherwise agreed between the Gateway and the ODFI. As between the Originator and the ODFI, the Originator bears all such risk, unless otherwise agreed between the Originator and the ODFI or required by Legal Requirements.


Questions about this ACH Operations Bulletin should be submitted via