Phase Two: ACH Contact Registry

Amy Donaghue

By: Emily Hays, AAP, APRP, NCP, Manager, Audit Services

We’ve all been there one time or another... Inevitably, a wonky ACH transaction will wreak havoc on your day, and you have no clue who to contact at the other financial institution to get your questions answered in a timely manner.

Recognizing this issue, Nacha came to the rescue with the ACH Contact Registry, which helps financial institutions identify who to contact with questions regarding ACH processing. This endeavor has been implemented in a phased approach.

Phase One: Creation of the ACH Contact Registry

As part of Phase One, which became effective July 1, 2020, Nacha expanded its ACH Risk Management Portal to include the ACH Contact Registry, aiming to provide financial institutions more easily accessible contact information for other organizations’ ACH and Risk Management specific areas.

Phase One of the ACH Contact Registry Rule became effective when the ACH Contact Registry opened and required all ACH Participating Depository Financial Institutions to register contact information for personnel or departments responsible for ACH operations and fraud and/or risk management areas. The contact information must include either a) the name, title, email address and phone number for at least one primary and one secondary contact person or b) general department contact information that includes an email address and a working telephone number.

Telephone numbers and email addresses provided within the Registry are to be monitored and answered by an individual(s) during normal business hours. An automated response or Voice Response System may not be sufficient contact for the ACH Contact Registry. The ACH Contact Registry allows financial institutions the opportunity to voluntarily provide additional contacts for ACH operations, fraud/risk management or other areas such as compliance, check, wire, credit card, AML, legal, etc.

The financial institution is responsible for ensuring the contact information is kept up to date, by updating the registered contact information within 45 days following any change to the information previously provided. As a best practice, it is recommended that financial institutions review this information on an annual basis to ensure compliance with the Rule, as well as develop procedures for accepting the incoming inquires to ensure a quick resolution. As a part of Phase One, all Participating DFIs were required to complete their registration by October 30, 2020.

Phase Two: Enforcement of the ACH Contact Registry

On August 1, 2021, Nacha implemented Phase Two of the ACH Contact Registry Rule (Article One, Section 1.14 Participating DFI Contact Registration). Under Phase Two, Nacha’s enforcement authority for the Rule became effective. Financial institutions that do not register appropriate contact information within the Nacha Risk Management Portal may be subject to an ACH Rules enforcement proceeding and fines at the Class 2 violation level. A Class 2 Rules Violation carries a fine of up to $100,000 per month until the problem is resolved.

Prior to October 30, 2020, the Nacha Registration Portal only required Originating Depository Financial Institutions to register their Direct Access and Third-Party Sender status. The updated Rule now also requires ALL financial institutions, including financial institutions who act as Receiving Depository Financial Institutions only, have access to the Nacha Risk Management Portal and register the appropriate contact information.

The Nacha Risk Management Portal can be accessed by clicking here. For any assistance in completing the requirements of the Rule or utilizing the Risk Management Portal please contact EPCOR’s Member Support Team (800.500.0100) or Nacha’s support line (703.349.4556).

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