Nacha has recently become aware of a problem involving the incorrect handling of Notifications of Change (NOCs) when an RDFI has recently divested a number of accounts. This Operations Bulletin is intended to remind ACH participants, and ODFIs and their Originators in particular, about the proper handling of changes requested via the NOC process.
In this instance, the selling RDFI transmitted NOCs for the specific accounts affected by the divestiture, requesting that the Originator update its database to incorporate the purchasing institution’s routing number for the transmission of any subsequent entries involving those particular accounts. Although the Originators (or their Third-Party Service Providers) acted on the change by correcting the accounts to which the NOCs directly related, they also applied the requested routing number change more broadly, erroneously believing that all accounts bearing the same original routing number should also be changed. The global application of this change resulted in a significant number of entries being transmitted to the wrong financial institution, causing an increased number of exceptions that had to be handled by the purchasing RDFI, as well as the delay of payments expected by Receivers.
When making a routing number change based on an NOC, an Originator should not assume that such a change should be applied to any other account unless it has taken steps to confirm, either with its ODFI or with the RDFI directly, that such a change is appropriate. A routing number may be changed for a number of reasons (including, but not limited to, merger, branch or account acquisition, or retirement of that particular routing transit number) which do not necessitate a similar change to other account numbers that share that particular routing number. When transmitting an NOC, the RDFI warrants to the ODFI that the change requested within the NOC is correct, and that, when required, the Receiver has authorized the change. This warranty does not extend beyond the specific Receiver’s account for which change is being requested.
Questions about this ACH Operations Bulletin should be submitted via email@example.com.