Third-Party Sender Services and Resources
Increased regulatory attention and compliance requirements directed toward Third-Party relationships has prompted EPCOR to develop specific, dedicated resources to aid Third-Party Senders and their ODFIs in understanding and meeting their risk and compliance obligations. We offer the following services and resources to assist you:
Third-Party Senders: Are You In Compliance?
If you answer NO to any of these questions, it may be time to contact EPCOR:
- Have you conducted your annual ACH Rules Compliance Audit?
- Have you conducted your annual risk assessment?
- Have you discussed Third-Party Sender registration or Third-Party Sender Certification with your ODFI?
ODFIs: Are You In Compliance?
If you answer NO to any of these questions, you too should consider contacting EPCOR:
- Have you identified your Third-Party Sender Originators? Have you looked at small CPA firms? Payroll Processing companies? Property Management Firms?
- Have your Third-Party Senders completed their annual ACH Rules Compliance Audit and an ACH Risk Assessment?
- Are you prepared to register your Third-Party Senders with NACHA on September 29, 2017? Do you know how to do so?
To learn more about Third-Party Sender compliance and EPCOR’s Third-Party Sender Services, contact Larry Matteson.
Third-Party Sender Registration
On September 29th of this year, the Third-Sender Registration ACH Rule goes into effect. This new rule will require all ODFIs to register with NACHA those Third-Party Senders whom they originate for. This is a big step in recognizing Third-Party Senders for what they are, valuable and trusted members of the electronic payments ecosystem.
While the Rule goes into effect in September, all Originating Depository Financial Institutions (ODFIs) have until March 1st of 2018 to complete the registration of their Third-Party Senders. This concession was offered to accommodate the work efforts that financial institutions are undergoing to implement the second phase of Same Day ACH.
NACHA’s website states "The registration process will promote consistent customer due diligence among all ODFIs, and serve as a tool to support NACHA’s continuing efforts to maintain ACH Network quality."
Initial registration consists of information that the ODFI should already be in possession of. This is:
- The ODFI and company contact information
- The name and principle business location of the Third-Party Sender
- The ODFI routing number used to originate ACH transactions
- The Company ID of the Third-Party Sender
Not only must ODFI’s register their principle Third-Party Senders, but they must also register any of that Third-Party Sender’s customers who are also Third-Party Senders (nested Third-Party Senders).
The registration process can be completed online at a website NACHA is developing. Information on that website will be forthcoming shortly. ODFI’s with a large number of Third-Party Processors to register can make arrangements with NACHA to submit a file of their processors.
The first step in compliance with this new ACH Rule is properly identifying Third-Party Sender relationships.
What does a Third-Party Sender look like?
NACHA’s Third-Party Sender Identification Tool is designed to assist ODFIs in identifying Third Party Sender relationships, such as Payroll Companies, CPA Firms and Property Management Firms to name a few.
EPCOR is also available to assist you with identifying these relationships. In addition to educational offerings, our Third-Party Services can provide on-site assistance as needed.
To find out more, contact Larry Matteson.
Want to learn more?
If you would like to learn more about NACHA’s Third-Party Sender Registration Rule, consider registering for one of the following learning events:
Third-Party Sender Guiding Principles
By agreeing to the Third-Party Sender Guiding Principles EPCOR’s Third-Party Sender members pledge to abide by 10 guidelines to demonstrate their integrity and commitment to compliance to the ACH Rules and all applicable laws, as well as ethical business practices regarding their financial institution partners, customers and the collective payments industry.
A Special Forum for Third-Party Senders and ODFIs
The EPCOR Third-Party Sender Forum is now called the TPS/ODFI Roundtable. This forum is open to all EPCOR Associate members and EPCOR ODFIs that originate for Third-Party Senders to allow for a unique space to collaborate on issues important to Third-Party payment processing. It is intended as a opportunity to discuss best practices and voice industry concerns in a friendly safe environment. The Roundtable meets once a month by teleconference. Those interested in learning more about the Roundtable should contact Larry Matteson.
Third-Party ACH Consulting Services
Designed to assist Third-Party Service providers and Third-Party Senders after completion of their annual ACH Rules Compliance Audit, the consult is a comprehensive review of current processes coupled with recommendations for improved compliance with the ACH Rules. We assist your organization in designing and implementing ACH compliance procedures and provide tools and resources to assist in your on-going business needs.
Third-Party ACH Audit Service
The NACHA Operating Rules require all participating depository financial institutions, Third-Party Service Providers and Third-Party Senders to conduct an annual ACH Rules Compliance Audit. We customize our ACH Rules Compliance Audits for a variety of Third-Party Service Providers and Third-Party Senders to ensure a comprehensive review of your unique processing environment.
EPCORs Third-Party Sender Committee
The Third-Party Sender Committee will resume meeting in August but we need a Third-Party Sender member to chair the committee. This Board approved committee will be tasked with working on solutions to issues confronting our Third-Party Sender members. Membership is limited to one person per Third-Party Sender organization. If interested in participating, please contact Larry Matteson.