By collaborating with ACH Operators, Regional Payments Associations and other industry partners, we’ve created a toolkit for payments professionals. Each resource and risk mitigation initiative balances the security of the ACH Network with innovation, allowing participants to keep information confidential while still expanding their payments capabilities.
When you use the Terminated Originator Database, you’re able to search for Originators or Third-Party Senders that have been terminated for cause, and you’re also performing part of your due diligence for “Know Your Customer.” Placement on the Terminated Originator Database, after being terminated for cause by one ODFI, doesn’t mean an Originator or Third-Party Sender is prohibited from working with another ODFI. However, it allows ODFIs to make educated business decisions about new Originators or Third-Party Senders and to keep the ACH Network safe.
The database plays a key role in NACHA’s Risk Management Strategy, and as ODFIs exchange information on terminated Originators or Third-Party Senders, they strengthen the Network. Fidelity Information Services (FIS), a world leader in banking and payments technology, maintains the database.
Being terminated for cause from ACH processing, as an Originator or Third-Party Sender, means forfeiting a contract to process ACH payments with an ODFI because of a specific regulation violation or compliance failure. NACHA encourages ODFIs to use the Terminated Originator Database in the following ways:
ODFIs may sign up for one of several options on the database: while all registrants pay a one-time setup fee, your organization can elect a per-month model, subscription model, or a combination of the two. Fees are nominal and depend on the size of your ODFI’s assets.
Because your financial institution works with a variety of companies, it can be difficult to quickly and easily determine the risk that each unique Originator or Third-Party Sender poses. To help your ODFI mitigate risks, NACHA maintains an Originator Watch List, which identifies Originators and Third-Party Senders that have met certain risk criteria. The companies on this list aren’t prohibited as customers, but NACHA encourages ODFIs to use the information as part of their risk assessment process and due diligence.
The Originator Watch List is available to employees of financial institutions that use the ACH Network, Regional Payments Associations and ACH Operators.
Financial institutions face heightened threats from illegal cyber activity, including data breaches and denial of service attacks. NACHA provides an Emergency FI Contact Database as a vehicle for communication during a crisis: financial institutions can collaborate and share information as needed to mitigate threats’ impact on day-to-day operations. This database is designed to include contact information for your financial institution’s key personnel responsible for coordinating threat response activity.