However, when a transaction involves the use of a payment intermediary (e.g., a Third-Party Service Provider that performs some aspect of payment processing on behalf of a client), those ACH roles may not always be easily identifiable. With the proliferation of new payment models, there is an undefinable amount of business-case scenarios, so documenting them all and the roles associated with each is not possible.
The Third-Party Sender Identification Tool was developed to help financial institutions and their ACH customers understand their roles when an intermediary is involved in some aspect of ACH payment processing. A payment intermediary can fill a variety of roles, depending on the nature of its arrangements with specific customers. ODFIs in particular are required to know the nature of their customers’ use of the ACH Network, whether as Originators, Third-Party Senders, or other types of intermediaries.
This Third-Party Sender Identification Tool is not intended to provide legal advice. Financial institutions are encouraged to obtain their own legal counsel regarding their obligations under the NACHA Operating Rules and other applicable legal requirements.