By Rhonda Broekemeier
In the world of payment processing the rules are in constant evolution. Are you aware of the recent changes that impact financial institutions? NACHA has new rules and amendments in 2019 your bank must know to remain ACH compliant.
Effective Jan. 1, 2019:
Automated Clearing House (ACH) rules compliance audit requirements
Appendix Eight has been removed from the guidelines and although the structure of audit requirements has changed, the requirement to conduct a compliance audit annually under NACHA rules. Banks who were replying on the Checklist in the appendix to conduct audits will need to review the Appendices and related language to be sure they are in compliance with all sections of the Rules. Annual audits should be structured based on the risks associated with their institution.
Effective Jun. 21, 2019:
Return for questionable transaction
This new rule allows banks to use an R17 return code if they believe an ACH entry was originated under questionable circumstances. Receiving Depository Financial Institutions (RDFIs) electing to use this code will add “QUESTIONABLE” in the addenda information field of the transaction. Originating Depository Financial Institutions (ODFIs) will be able to differentiate the returns from the routine account number errors.
Effective Sept. 20, 2019:
Providing faster funds availability
This new rule applies to certain Same Day ACH and next-day ACH credits. For banks that are already real-time posting transactions when they are received and processed, you will already be in compliance. ODFIs should inform all Originators and third party senders that all Same Day, and certain next day credits will be available for withdrawal by receivers no later than 9:00 am local time.
For banks that are not currently posting real-time, this change results in the posting of ‘Same Day’ ACH credits twice per business day, one by 1:30 p.m. and the second by 5:00 p.m. local time.
For further details on these changes and new changes in the upcoming year, refer to the 2019 NACHA Operating Guidelines and Supplement #1-2019, amendment to the guidelines.
