In most ACH transactions, the roles of the various parties to the transaction (e.g., Originator or Receiver) are well understood. When a transaction involves a Third-Party Sender or other payment intermediary, however, roles can become confused. Although the proliferation of new payment models makes it impossible to catalogue all the different fact patterns that may arise, this ACH Operations Bulletin is intended to provide some representative examples that should help participants and observers properly categorize the roles of the parties in payment scenarios involving different types of third party payment intermediaries, and understand how ACH transactions should be identified for consumers. Note: This ACH Operations Bulletin is for information purposes only, and is intended to provide general guidance regarding certain principles regarding the interpretation of the NACHA Operating Rules. All applications of the NACHA Operating Rules are subject to the facts and circumstances of the specific case. This ACH Operations Bulletin is not intended to provide legal advice. Readers should obtain their own legal advice regarding their obligations under the NACHA Operating Rules or applicable legal requirements.