Effective September 29, NACHA’s Third-Party Sender Registration Rule will go into effect, and require that originating depository financial institutions (ODFI) submit and maintain information on every third-party sender with which it maintains a relationship.  A third-party sender is a processing intermediary between a financial institution and an end-user of ACH payments.  The Rule will require ODFIs to provide information regarding each third-party relationship it maintains.

Information required for third party senders includes the name and principle business location of the third-party sender, the routing number used in ACH transactions for the third-party sender, and the Company Identification(s) of the third-party sender.  In addition, the ODFI is obligated to provide more detailed information on third-party senders within ten business days of written notice, in cases where NACHA believes a specific third-party sender poses an escalated risk to the network.

If the credit union does not have any third-party sender relationship members, it will still be required to provide a statement to that effect.

NACHA has developed a Third-Party Sender Identification Tool, and an Operations Bulletin that provides examples to help categorize the parties in payment scenarios.  More information about the Third-Party Sender Rule is available here, and on our blog here.