Any database is only as good as the information it contains, and the ACH Contact Registry is no exception.
Although enforcement of the Registry Rule doesn’t begin until Aug. 1, Nacha is already making spot-checks for data quality.
The Rule requires that phone numbers and email addresses listed in the ACH Contact Registry be monitored during normal business hours. But Nacha has received reports about cases where that’s not occurring, or where the numbers and emails are incorrect.
“We are conducting random checks of what’s already in the database,” said Lorie Nash, Nacha Senior Director of Compliance. Members of Nacha’s compliance and risk teams have been joining forces on this since June 1.
“If we call and leave a message, are the messages being returned? If we send an email, is it being responded to in a timely manner?” said Nash.
Working off the more than 36,000 contacts entered since the Registry opened July 1, 2020, spot-checks are being made in what Nash stressed is a strictly random manner.
“If they answer the phone, we let them know who we are, what we’re doing, why we’re doing it,” said Nash. “It’s usually a pleasant chat when we let them know they’ve passed that portion of the audit. And then we let them know to follow up on the email that’s coming,” said Nash.
The emails that are sent are similar, with an explanation of what’s going on, and a request to simply respond with “received.”
For financial institutions that don’t acknowledge the calls or emails, no enforcement action is being taken at the moment. “But we are tracking the outcome,” said Nash.
“Failure to complete the process of registering contact information in the registry is a Class 2 level violation and could be subject to a fine,” she said, stressing that Nacha “greatly prefers to see ACH Network participants voluntarily comply with the Rules. Enforcement actions and fines are always a last resort.”
The ACH Contact Registry is securely housed on Nacha’s Risk Management Portal, where information is available only to registered FIs, Payments Associations and the two ACH Operators.
“Nacha is grateful to the financial institutions that have stepped up to honor their obligations under the Nacha Operating Rules by registering their information,” said Jeanette Fox, Nacha Senior Director, Risk Investigation & ACH Network Risk Management. “Gathering the necessary information and then entering it should not be a heavy lift for any bank or credit union. And as a reminder, FIs should make sure their information remains current, and make any updates in the Registry within 45 days of a change.”
Learn more about the ACH Contact Registry on the Rules section of Nacha.org.
If you’re ready to enter your information on the ACH Contact Registry, go to the Risk Management Portal.
For assistance, Nacha’s Portal support number is 703-349-4556, or you can email email@example.com.