Supplementing Data Security Requirements

This change to the NACHA Operating Rules will enhance quality and improve risk management within the ACH Network by supplementing the existing account information security requirements for large-volume Originators and Third-Parties. This change will be implemented in two phases.

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Detailed Information

The existing ACH Security Framework including its data protection requirements will be supplemented to explicitly require large, non-FI Originators, Third-Party Service Providers (TPSPs) and Third-Party Senders (TPSs) to protect deposit account information by rendering it unreadable when it is stored electronically.

Implementation begins with the largest Originators and TPSPs (including TPSs) and initially applies to those with ACH volume of 6 million transactions or greater annually. A second phase applies to those with ACH volume of 2 million transactions or greater annually.

This Rule modifies the following areas of the NACHA Operating Rules:

Article One, Section 1.6 (Security Requirements) to require each Non-Consumer Originator that is not a Participating DFI, each Third-Party Service Provider, and each Third-Party Sender, whose ACH Origination or Transmission volume exceeds 6 million Entries annually  to protect DFI Account Numbers used in the initiation of Entries by rendering them unreadable when stored electronically.

Effective Dates:

  • Phase 1 – June 30, 2020 for Originators and Third-Parties with ACH volume greater than 6 million in 2019
  • Phase 2 – June 30, 2021 for Originators and Third-Parties with ACH volume greater than 2 million in 2020

Potential Impacts:

  • Implementation for those Originators and Third-Parties that currently would not be compliant
  • For ODFIs, informing Originators of their direct compliance obligations

Coming soon

There were 83 respondents to the Request for Comment. 80% of those responding supported the proposal and 88% agreed that the rule should not mandate specific data security methods or techniques.