REMINDER OF YOUR RESPONSIBILITY TO NOT EXCEED UNAUTHORIZED ACH RETURN LEVELS

The current return rate threshold for unauthorized debit Entries is .05%. All Originators and Third-Party Senders that exceed this limit, are required to immediately reduce this percentage and maintain a below threshold return rate. 

These return reason codes include:

ACH Originators should be aware of and train all new and existing staff on the importance of monitoring for unauthorized activity over a 60-day period. This becomes even more important based on external fraud threats. An ODFI that has an Originator that breaches this unauthorized threshold would be subject to the same obligations and potential enforcement as currently outlined in the Rules.

To ensure you fall below this threshold, it is recommended to implement the following internal controls:

• Review/develop reporting to monitor and track unauthorized debit return rates
• Implement a monitoring/notification process with your ODFI when unauthorized activity is close to this threshold limit
• Report on any recurring unauthorized activity and resolve all unauthorized returns prior to initiating the live entry back into the network
• For additional information regarding network unauthorized return threshold requirements, contact your designated account officer. 

Update on Upcoming NACHA Operating Rules

There are some new and upcoming Nacha Rules [“Rules”] that are important to share with your internal teams. These Rules cover the micro-debit dollar amounts and the increase in the Same Day ACH item amount. Both of these Rules are significant in the modernization and improvement of the ACH network. 

Account Validation:

Micro-Credits

Micro-credits are used to test the validity of an account and are used as one of the ways Originators of WEB debits are validating the account as a fraud tool before initiating future WEB debits. In addition, micro-credits are also used to test the validity of accounts for online account opening. Nacha approved a Rule that will define and standardize practices and formatting of Micro-Entries. This new Rule defines Micro-Entries” as ACH credits of less than $1, and any offsetting debits, for account validation. This Rule will be rolled out in two phases including:

Phase 1

Effective Sept. 16, 2022:

• Requires that credit amounts must be equal to, or greater than, debit amounts, and must be transmitted to settle at the same time.
• Originators must use “ACCTVERIFY” in the company entry description field. 
• Company name must be easily recognizable to Receivers and the same or similar to what will be used in subsequent entries.

Phase 2

Effective March 17, 2023:

• Originators must use commercially reasonable fraud detection. This includes monitoring forward and return Micro-Entry volumes.

Reminder of Same Day ACH Item to $1MM

Effective March 22, 2022

As a reminder, the Same Day ACH dollar amount per item was increased to 1MM for each individual Same Day ACH entry and applies to both debits and credits.   This limit is only for the Same Day ACH individual entries and not for next-day transactions. Entries submitted in a same-day processing window that is over $1MM will not be rejected by the ACH Operator but will be processed for next-day settlement in the next available processing window.