ACH Third-Party Senders:

• Initiate ACH transactions on behalf of an originator or another Third-Party Sender when there is not an origination agreement directly between the originator and the Originating Depository Financial Institution (ODFI).
• Have many of the same responsibilities as an Originating Depository Financial Institution (ODFI) under the Nacha Operating Rules and Guidelines (Nacha Rules).

Your agreement with U.S. Bank allows us to conduct a review to ensure your compliance with the Nacha Rules. Non-compliance could result in a termination of service.

As an ACH Third-Party Sender, you have specific responsibilities and requirements under the Nacha Operating Rules. We’ve consolidated information and resources to assist with your fulfillment of these requirements.

• Third-Party Sender checklist
• Resources for Nacha self-audit 
• Nacha video: What Is a Third-Party Sender?
• Nacha’s explanation of Third-Party Sender roles and responsibilities
• Nacha’s Third-Party Sender identification tool

Phase 2 – March 17, 2023

This rule will define and standardize practices and formatting of Micro-Entries, which are used by some ACH originators as a method of account validation.

Implemented March 18, 2022

This rule change will continue to expand the capabilities of Same Day ACH. The per transaction dollar limit will be increased to $1 million dollars on the effective date.

Implemented September 30, 2022

This rule change will clarify the roles and responsibilities of third-party senders in the ACH network. The rule change addresses the practice of using nested third-party senders, and explicitly requires the third-party sender to conduct a risk assessment.

Implemented June 3, 2022 – Phase 2

High volume ACH originators who originate over two million items annually across all their origination banks must protect bank account numbers by rendering them unreadable when stored electronically. These originators will need to review and potentially update their data security efforts to be in compliance by June 30, 2022.

Phase 1 – September 16, 2022