ACH Third-Party Senders:

• Initiate ACH transactions on behalf of an originator or another Third-Party Sender when there is not an origination agreement directly between the originator and the Originating Depository Financial Institution (ODFI).
• Have many of the same responsibilities as an Originating Depository Financial Institution (ODFI) under the Nacha Operating Rules and Guidelines (Nacha Rules).

Your agreement with U.S. Bank allows us to conduct a review to ensure your compliance with the Nacha Rules. Non-compliance could result in a termination of service.

As an ACH Third-Party Sender, you have specific responsibilities and requirements under the Nacha Operating Rules. We’ve consolidated information and resources to assist with your fulfillment of these requirements.

• Third-Party Sender checklist
• Resources for Nacha self-audit 
• Nacha video: What Is a Third-Party Sender?
• Nacha’s explanation of Third-Party Sender roles and responsibilities
• Nacha’s Third-Party Sender identification tool

Effective June 21, 2024

These changes are minor amendments to the Nacha rules with little to no impact on ACH participants.

• General Rule for WEB Entries: This rule change establishes the WEB SEC code must be used for all consumer-to-consumer credits, regardless of how the consumer communicated the payment instructions. 
• Definitions of Originator: Expands the definition of Originator as the party authorized by the Receiver to credit or debit the Receiver’s account at the RDFI. 
• Originator Action on Notification of Change (NOC): This rule change gives Originators discretion to make NOC changes for any Single Entry, regardless of SEC Code. 
• Data Security Requirements: This rule change clarifies that an Originator must continue to adhere to the Data Security Requirements going forward once they reach the threshold of 2 million originated transactions. The current rules give the Originator until June 30 the year following to be compliant. 
• Use of Prenotification Entries: This rule change is removing language that limits prenote use to only prior to the first credit or debit entry. 
• Clarification of Terminology – Subsequent Entries: This rule change adjusts prenote and NOC language to remedy now-ambiguous references to the use of the term “subsequent entry.”

Effective October 1, 2024

These rule changes are all related to efforts to reduce credit push fraud in the ACH network, and to increase the likelihood of funds recovery when fraud has occurred.

• Codifying Expanded Use of Return Reason Code R17: This rule will explicitly allow, but not require, an RDFI to use R17 to return an entry that it thinks is fraudulent.
• Additional Funds Availability Exceptions: This rule provides RDFIs with an additional exemption from the funds availability requirements to include credit entries that the RDFI suspects are originated under false pretenses.
• Timing of Written Statement of Unauthorized Debit: This rule will allow a Written Statement of Unauthorized Debit to be signed and dated by the Receiver on or after the date on which the entry is presented to the Receiver. This may help prevent harm to the Receiver if they determine a transaction is fraudulent before it will post.
• RDFI Must Promptly Return Unauthorized Debit: This amendment will require that when returning a consumer debit as unauthorized in the extended return timeframe, the RDFI must do so by the opening of the sixth banking day following the completion of its review of the consumer’s signed Written Statement of Unauthorized Debit.

Effective April 1, 2025

• Expanded Use of ODFI Request for Return/R06: This rule expands the permissible uses of the Request for Return to allow an ODFI to request a return from the RDFI for any reason.

Effective March 20, 2026

These rule changes establish requirements for the content of the Entry Description field for specific types of transactions. These changes are part of a comprehensive approach to reduce fraud risks in the ACH network.

• PPD credits for the payment of wages, salaries, and similar compensation must use the value of PAYROLL in the Entry Description field for a batch containing those transactions.
• WEB debits for the online purchases of goods, including recurring purchases first authorized online, must use the value of PURCHASE in the Entry Description field for a batch containing those transactions.
• These are “no later than” dates, Originators may begin using the descriptions as soon as practical.

Effective March 20, 2026

These rules changes will be implemented in two phases and are part of a comprehensive approach to reduce fraud risks in the ACH network to improve the chances of recovery when fraud has occurred. They require certain ACH participants to establish and implement risk-based processes and procedures reasonably intended to identify ACH Entries initiated due to fraud.

• Phase 1 applies to all originators, third-party senders, and third-party service providers that originated more than 6 million ACH transactions in 2023.
• Phase 1 also applies to all banks that received over 10 million ACH transactions in 2023.

Effective June 22, 2026

These rules changes will be implemented in two phases and are part of a comprehensive approach to reduce fraud risks in the ACH network to improve the chances of recovery when fraud has occurred. They require certain ACH participants to establish and implement risk-based processes and procedures reasonably intended to identify ACH Entries initiated due to fraud.

• Phase 2 applies to all originators, third party senders, and third-party service providers that did not meet the threshold for Phase 1, as well as all banks that receive ACH transactions that did not meet the threshold for Phase 1 (effective March 20, 2026).

Phase 2 – March 17, 2023

This rule will define and standardize practices and formatting of Micro-Entries, which are used by some ACH originators as a method of account validation.