Payments SmartCast

Learn from the Experts: Third-Party Senders and the ACH Network

Jan 4, 2023
Danita Tyrell, Senior Director of ACH Network Rules Development at Nacha, and Jordan Bennett, Senior Director of ACH Network Risk Management at Nacha, dive into the latest updates on third-party senders in the ACH Network. They discuss evolving operating rules and new risk management practices, emphasizing the significance of recent changes set for September. With real-world examples, they highlight how banks should uniquely approach third-party relationships and the challenges of nested arrangements. Their insights empower organizations to navigate ACH innovations effectively.
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INSIGHT

Evolution Of Third-Party Sender Rules

  • Third-party senders evolved alongside ACH rules, which now explicitly address their roles and risk assessments.
  • The updated publication acts as an advanced companion to the NACHA Operating Rules for complex third-party relationships.
ADVICE

Make Risk Assessments Explicit

  • Perform an explicit risk assessment as required under the new rules effective September 30.
  • Make risk assessments a documented and repeatable part of third-party sender oversight.
ADVICE

Treat Third-Party Senders Differently

  • ODFIs should treat third-party senders differently than originators and apply tailored risk models.
  • Use the publication's examples and risk tips to identify third-party senders and adjust onboarding and oversight.
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