ACH Processing and Compliance Manual

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The Manual brings you information you need to keep on top of the latest changes in the field of ACH processing. Written in an easy-to-understand format, this manual reviews the basis and structure of all ACH processing – the NACHA Rules. This manual includes Information on both receiving and origination. Recent and upcoming changes to the Rules including: Third-Party Senders and “Nested” Third-Party Senders; increased dollar limit on Same-Day ACH Entries; operational benefits from Meaningful Modernization; and Supplementing Data Security Requirements – 2022 Impacts are discussed in detail. Recent proposed Rules changes including Account Information Improvements, and a possible proposal arising from the RFI on Risk of Early Funds Availability are reviewed. The annual expansion of and enhancements to the ACH “self-audit” are thoroughly discussed, and the federal ACH examination is highlighted.

Treasury’s Green Book – A Guide to Federal Government ACH Payments and Collections is discussed with a focus on the reclamation process, and Treasury’s triennial updates to 31 CFR 210. An update is also provided on Treasury’s ongoing efforts to expand direct deposit and the utilization of “Go Direct®”.

Compliance issues including OFAC impacts to ACH processing, suspicious activity reporting (SAR), the federal focus on ACH as part of the annual Bank Secrecy Act (BSA) examination efforts, and the standardization of the garnishment of exempt federal benefits payment processing, are all highlighted. Major areas of ACH risk are addressed, including methods and procedures to minimize risk exposure.

​TOPICS

New and Recent NACHA Rules

  • Expanded Same Day ACH: Dollar Limit Increase
  • Differentiating Unauthorized Return Reasons
  • Supplementing Data Security Requirements
  • ACH Contact Registry
  • Supplementing Fraud Detection Standards for WEB Debits
  • Expanded Same Day ACH: Additional Processing Window
  • ACH Message Entries (proposed)

The Latest on Federal Government Payments & Processing

  • The Green Book – On-Line PDFs
  • 31 CFR Part 210 – 2020 Update
  • Reclamation Process/IRS Tax Refund Processing FAQs
  • Direct Deposit and “Go Direct®” updates

2020 Audit and Examination Guidelines

  • Annual Self-Audit Procedures-2020 Focus Points
  • Federal Audit Guidelines on ACH

Processing Risks

  • Fraud
  • Operational
  • Credit
  • Systemic
  • Compliance
  • Reputational
  • Strategic
  • Terminated Originator Database (TOD)

Regulatory Impacts

  • BSA Examination impacts to ACH Processing
  • Suspicious Activity Reporting (SAR) – Impacts to ACH Operations
  • OFAC – Updated Impacts to ACH Operations
  • Garnishment of Exempt Federal Benefit Payments – Impacts to ACH Operations

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