ACH Processing and Compliance
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Electronic Item No: EM-ACH
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This 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 discussion on both receiving and origination. Recent changes to the Rules including: Micro-Entries; “Nested” Third-Party Senders; operational benefits from Meaningful Modernization; and the 2024 impacts from the ACH Contact Registry, R11 utilization, and ACH quality topics are discussed in detail. Recent proposed Rules changes (9) on Risk Management and credit-push fraud, and possible Rules proposals (4) arising from the May 2023 RFI on ACH Risk Management 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 included with a focus on the updated reclamation process, and the 2024 modifications (if any) to the Green Book. 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
- Credit-Push Fraud – 9 Proposed Rules Changes – (expected to be balloted)
- Micro Entries
- “Nested” Third-Party Senders
- Supplementing Data Security Requirements – 2024 Impact
- ACH Contact Registry – 2024 Impact
- Meaningful Modernization – operational benefits
- Risk Management Topics (4 possible proposed Rules)
The Latest on Federal Government Payments & Processing
- The Green Book – On-Line PDFs
- 31 CFR Part 210
- Reclamation Process/IRS Tax Refund Processing
- Direct Deposit and “Go Direct®” updates
2024 Audit and Examination Guidelines
- Annual Self-Audit Procedures-2024 Focus Points
- Federal Audit Guidelines on ACH
Processing Risks
- Fraud
- Operational
- Credit
- Systemic
- Synthetic Identity Fraud
- Compliance
- Reputational
- Strategic
- Terminated Originator Database (TOD)
- Federal Third-Party Risk Management Guidance
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