ACH Audit Services

Since the publication of the 2009 edition of the ACH Rules, NACHA's Voting Membership has approved one additional amendment to the NACHA Operating Rules (Rules).  This amendment, which will become effective December 18, 2009, will refine and clarify existing Rules compliance audit requirements for all Participating DFIs, with specific provisions for ODFIs and RDFIs.  These revisions will result in more effective annual audits, which will promote improved Rules compliance and higher quality transaction processing. Compliance with the revised audit provisions is not mandatory until the 2010 audit year; however, earlier adoption of these audit provisions is encouraged for all DFIs to mitigate areas of potential risk caused by non-compliance with the Rules. The specific details of the changes resulting from these amendments are outlined within the attached documents.

This Supplement #1-2009 also updates the NACHA Operating Guidelines related OFAC compliance. NACHA developed recommendations and guidance for Gateway Operators and RDFIs for processing inbound IAT debits in accordance with OFAC requirements. This guidance, which was originally issued in December 2008, was in response to a number of requests that NACHA had received from ACH Network participants that are considering how they will handle such debits, and that wish to do so in a manner that is as automated as possible.

Effective March 5, 2009, OFAC revised its requirements and expectations regarding the handing of inbound IAT debits. As a result, NACHA's previous guidance on processing inbound IAT debits, which was designed to meet OFAC's original expectations, is no longer valid.  The chapter on OFAC compliance within this supplement replaces that found in Section IV, Chapter IV - OFAC Compliance of the 2009 NACHA Operating Guidelines.

Visit the NEACH Resource Library to view ACH Rules Supplement #1. (Login Required)