Nacha's Upcoming ACH Contact Registry Rule Requirement

6/4/2020

Financial institutions constantly seek ways to contact and communicate quickly with other financial institutions about specific ACH payment issues and exceptions. Nacha created the ACH Contact Registry Rule (the Rule) to help facilitate this process. Make sure that you are aware, informed, and ready to register with Nacha. Included are some frequently asked questions and answers regarding this upcoming requirement.

What is the ACH Contact Registry Rule?

The Rule requires financial institutions to register contact information with Nacha for personnel or departments responsible for ACH operations and fraud/risk management. The contact information will be made available to other registered financial institutions, Payments Associations, the ACH Operators, and Nacha for operational, fraud, and risk management issues in the ACH Network (e.g., proof of authorizations, ACH-related system outages, erroneous payments, duplicates, reversals, fraudulent payments, etc.).

Where do I register and is there a charge to register?

Registration will be performed through Nacha’s website via the Risk Management Portal and there is no fee to register.

What is the effective date?

Effective July 1, 2020, the registration portal will be available to begin to submit and query contact information. To stay compliant with Nacha, financial institutions must complete the registration by October 30, 2020.

Who does this Rule apply to?

All financial institutions participating in the ACH Network must register.

How does this Rule impact ODFIs?

Currently, Nacha requires all ODFIs to register their Direct Access status and Third-Party Sender status via Nacha’s Risk Management Portal. Under this new Rule, ODFIs will be required to perform an additional registration and provide their own contact information for ACH operations and keep that information current.

How does this Rule impact RDFIs?

Currently, Nacha does not require financial institutions that are only RDFIs to register information via Nacha’s Risk Management Portal. Under this new Rule, all RDFIs will be required to register contact information for ACH operations and keep that information current.

What are some examples of use cases for the ACH Contact Registry?

An ODFI needs to contact an RDFI about an ACH credit that is suspected to be fraudulent
An RDFI needs to contact an ODFI regarding the authorization of an ACH debit
An ODFI needs to contact an RDFI about a duplicate ACH payment, request the RDFI to return an entry, or request a copy of a WSUD

What type of contact information is required to be registered?

Specific contact information for personnel or departments responsible for ACH operations and fraud/risk management. The financial institution will be required to register either:

the name, title, email address, and phone number for at least one primary and one secondary contact person; or
general department contact information that includes an email address and a working telephone number.

Registered phone numbers and email addresses must be those that are monitored and answered during normal business hours for financial institution inquiries. For more information, you can visit Nacha’s website.

Questions?

If you have any questions or need assistance, email paymentadvisors@saltmarshcpa.com or a member of our Financial Institutions Team so we can help.

About the Bank Advisors

The Bank Advisors at Saltmarsh have provided audit, tax and consulting services to a wide range of financial institutions since our founding in 1944, making it the firm’s largest specialty practice and industry of focus. Our Financial Institution Advisory Group has the talent, expertise and insight to help you and your institution thrive. Our team members are also industry leaders who have the knowledge and experience to provide you with unparalleled service and guidance.