A non-consumer customer of the ODFI that has entered into an agreement with the ODFI to originate ACH entries to Receivers' accounts at an RDFI.

Payroll Direct Deposit Credits

Corporate Account Transfers

Utility Debit Payments

Gym Dues Payments

A non-consumer customer of the ODFI that is engaged in originating ACH entries on behalf of their Clients to Receivers accounts at an RDFI. The ODFI will have an agreement directly with the Third-Party Sender and not with the Third-Party Sender’s Originators.

Payroll and Tax Processors

CPA Firms

Collection Agencies

Merchant Services Providers

Property Management Companies

• ODFI must have an agreement with the Third-Party Sender containing the Nacha Operating Rules requirements for such agreements (Article Two, Subsection 2.2.2.2)

• ODFI must utilize a commercially reasonable method to verify the identity of a Third-Party Sender at the time the ODFI enters into an Origination Agreement with the Third-Party Sender (Article Two, Subsection 2.2.1

• ODFI must assess the risk associated with the Third-Party Sender's origination activity (Article Two, Subsection 2.2.3 a)

• ODFI must establish, enforce and periodically review an exposure limit (Article Two, Subsection 2.2.3 b)

• ODFI must monitor exposure limits across multiple settlement dates, enforce restrictions on the types of entries that may be originated, and the enforce exposure limit (Article Two, Subsection 2.2.3 c)

• ODFI must keep Third-Party Senders informed of their responsibilities under the Rules (Article Two, Section 2.1)

• ODFI must provide information relating to an NOC to Third-Party Senders within two banking days of the settlement date of the NOC (Article Two, Section 2.11)

• ODFI must register with Nacha each Third-Party Sender for which it originates entries including 1) a Third-Party Sender that originates entries through another Third-Party Sender customer of the ODFI; and 2) a Third-Party Sender that originates entries through Direct Access (Article Two, Subsection 2.17.3)

• TPS must have an agreement with the Originator containing the Nacha Operating Rules requirements for such agreements (Article Two, Subsections 2.2.2.1 and 2.2.2.2)

• TPS must utilize a commercially reasonable method to verify the identity of an Originator or nested Third-Party Sender at the time the TPS enters into an Origination Agreement with the Originator or nested Third-Party Sender (Article Two, Subsection 2.2.1

• If TPS is processing corporate ACH credits (CCD, CTX) entries on behalf of Originators, the TPS must provide Originator with proper notice of UCC Article 4A either in the service agreement or by other method (Article Two, Subsection 2.3.3.2)

• TPS must assess the risk associated with origination activity (Article Two, Subsection 2.2.3 a)

• TPS must establish, implement and periodically review an exposure limit for each Originator or nested Third-Party Sender (Article Two, Subsection 2.2.3 b)

• TPS must monitor Originator or nested Third-Party Sender's origination and return activity over multiple settlement dates, enforce restrictions on types of entries that may be originated, and enforce the exposure limit (Article Two, Subsection 2.2.3 c)

• TPS must keep Originators informed of their responsibilities under the Rules (Article Two, Section 2.1)

• TPS must provide information relating to an NOC to Originators within two banking days of the settlement date of the NOC (Article Two, Section 2.12)

• TPS must conduct an ACH risk assessment of ACH activities and implement a risk management program based on the results of the risk assessment (Article One, Subsection 1.2.4 and Guidelines Chapter 4, General Rules, Risk Assessments)

• TPS must conduct an annual ACH Audit of its compliance with the Nacha Operating Rules no later than December 31 of each year. (Article One, Subsection 1.2.2)

• TPS must disclose to the ODFI any Nested Third-Party Sender for which it transmits entries to the ODFI, prior to transmitting entries for the Nested Third-Party Sender (Article Two, Subsection 2.16.2)

• TPS must, upon the ODFI's request, provide the ODFI with any information the ODFI reasonably deems necessary to identify each Originator or Nested Third-Party Sender for which the TPS transmits entries. The TPS must also, upon the ODFI's request provide the ODFI with the information required for the purposes of the ODFI's registration of the TPS with Nacha. The information must be provided by the TPS within two banking days of receipt of the ODFI's request (Article Two, Subsection 2.15.1)

A service provider to an RDFI, ODFI, Originator or Third-Party Sender for the purpose of processing ACH transactions.

Financial Institution Core Processor

Correspondent Bank

ACH Origination Service Provider

Bill Payment Provider

• ODFI must have an agreement with all Third-Party Service Providers that transmit ACH entries on the ODFI’s behalf to an ACH Operator (Article Two, Subsection 2.2.2.3)

• Third-Party Service Provider to an RDFI/ODFI or Third-Party Sender must conduct an annual ACH Audit of its compliance with the Nacha Operating Rules no later than December 31 of each year (Article One, Subsection 1.2.2)