Industry Alerts

Industry Alerts

Industry Alerts provides member financial institutions with critical information; such as changes to the NACHA Operating Rules, Requests for Comment, notices from Treasury, NEACH cancellations, and other important and often time-sensitive information. This is a members-only resource. Login for access.  


 

Reminder Regarding ACH Responsibilities to Financial Institutions Potentially Impacted by Coronavirus

ACH Operations Bulletin #2-2020
Reminder Regarding ACH Responsibilities to Financial Institutions Potentially Impacted by Coronavirus

 

In light of the potential impact of coronavirus, Nacha reminds financial institutions of the importance of reviewing their business continuity plans to ensure that they are prepared to maintain ACH payment processing capabilities in the event of possible disruptions. In addition to their own business continuity plans, financial institutions should understand the expectations of their regulators and ACH Operators with regard to ACH processing in potential scenarios of workforce disruption.

The Nacha Operating Rules permit a financial institution to delay performance of its obligations under the Rules beyond required time limits if:

1. The delay was caused by the interruption of communication or computer facilities; and,

2. The delay was beyond the reasonable control of the financial institution seeking the excused delay.

Whether a delay is beyond the reasonable control of the party asserting an excused delay must be determined based on the available facts and circumstances surrounding the delay, including whether the financial institution exercised the level of diligence required under such circumstances. A delay caused, in whole or in part, by the failure of a financial institution to maintain or implement an appropriate business continuity plan is not excused under the Rules for that financial institution.

Access the ACH Operations Bulletin #2-2020 - Reminder on ACH Responsibilities to Financial Institutions Potentially Impacted by Coronavirus in the resource center.

As a reminder, NEACH offers a free session on excused delay: There’s Snow, There’s Rain, There’s Wind, Oh MY!  Please consider registering for this free session and keeping your staff informed.