Approximately six months ago, Nacha issued several ACH Operations Bulletins and Frequently Asked Questions announcing relief from a variety of requirements of the Nacha Operating Rules due to the impact of the coronavirus pandemic.

Businesses that originate pre-authorized ACH debits for services that have been interrupted may face an elevated risk of returns.

The Nacha Rules require an RDFI to accept a consumer’s Written Statement of Unauthorized Debit (WSUD), and also require that the WSUD be signed or similarly authenticated.

The upcoming effective dates of the Rule on Supplementing Data Security Requirements are extended by one year, to June 30, 2021 and June 30, 2022, respectively. The effective dates of other approved and upcoming Rules remain in effect.

In light of the current need for organizations to reduce on-site staffing levels, Nacha is providing temporary relief from deadlines for delivery of certain records that are required under the Nacha Rules. 

Nacha reminds financial institutions of the importance of reviewing their business continuity plans to ensure that they are prepared to maintain ACH payment processing capabilities in the event of possible disruptions.

The March 19, 2021 effective date for the new Same Day ACH processing window is confirmed.  

The upcoming effective date of the rule on Supplementing Fraud Detection Standards for WEB Debits is extended from January 1, 2020 to March 19, 2021. This extension is in response to industry requests to allow additional time for awareness, education and implementation.

The rule establishing the current Unauthorized Entry Fee provides that the amount will be re-evaluated every three years, with the initial 3-year period ending on September 30, 2019. The amount of the Unauthorized Entry Fee will remain at $4.50 per covered return during the next 3-year period, through September 30, 2022.

The effective date of the new Same Day ACH processing window is deferred by 6 months until March 19, 2021. The Federal Reserve Board of Governors (“Fed Board”) has informed Nacha that it will not be able to provide timely notification of its approval for Federal Reserve services necessary to enable the new window by the deadline provided for in the rule.

Nacha is publishing the attached form, entitled “Indemnification Agreement – Request for Return of Funds from ACH Entry” (“Indemnification Agreement”), for use by financial institutions in certain situations in which an ODFI requests the return of funds from an ACH transaction, and the RDFI desires to receive a written indemnification in addition to the indemnification contained in the Nacha Operating Rules (“Rules).”

Nacha is publishing the attached form, entitled “Indemnification Agreement – Request for Return of Funds from ACH Entry” (“Indemnification Agreement”), for use by financial institutions in certain situations in which an ODFI requests the return of funds from an ACH transaction, and the RDFI desires to receive a written indemnification in addition to the indemnification contained in the Nacha Operating Rules (“Rules).”

Nacha is publishing the attached form, entitled “Indemnification Agreement – Request for Return of Funds from ACH Entry” (“Indemnification Agreement”), for use by financial institutions in certain situations in which an ODFI requests the return of funds from an ACH transaction, and the RDFI desires to receive a written indemnification in addition to the indemnification contained in the Nacha Operating Rules (“Rules).”

Nacha is publishing the attached form, entitled “Indemnification Agreement – Request for Return of Funds from ACH Entry” (“Indemnification Agreement”), for use by financial institutions in certain situations in which an ODFI requests the return of funds from an ACH transaction, and the RDFI desires to receive a written indemnification in addition to the indemnification contained in the Nacha Operating Rules (“Rules).”

Nacha is publishing the attached form, entitled “Indemnification Agreement – Request for Return of Funds from ACH Entry” (“Indemnification Agreement”), for use by financial institutions in certain situations in which an ODFI requests the return of funds from an ACH transaction, and the RDFI desires to receive a written indemnification in addition to the indemnification contained in the Nacha Operating Rules (“Rules).”

The following question and answer format is intended to provide guidance to RDFIs in responding to the needs of their account holders while remaining in compliance with the requirements of the Nacha Operating Rules.

Use of the PPD Standard Entry Class Code for the conversion of consumer checks accepted at the point of purchase for payment of goods and services is not expressly recognized under the Nacha Operating Rules, as the POP application was designed with the express purpose of converting checks at the point of purchase. 

The following question and answer format is intended to provide guidance to RDFIs in responding to the needs of their account holders while remaining in compliance with the requirements of the Nacha Operating Rules.