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#1785318 - 02/12/13 08:40 PM ACH and third party senders
mmpaudit Offline
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Joined: Jan 2013
Posts: 7
My bank sends our employee payroll information to a third party for processing, the third party then sends us back the file and we originate the ACH entry. We are the originator and ODFI. Do we need a separate agreement with the third party sender above what is in place for performing payroll services? It is a strange situation and does not seem clear cut to me. Subsection 2.2.1.2 of the NACHA rules says yes, but I wondered if anyone else has run into the same situation? Any thoughts are appreciated.

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Audit
#1796337 - 03/19/13 07:11 PM Re: ACH and third party senders mmpaudit
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
As you describe it, the payroll processor is not a third-party sender. You are the sender, the Originator and the ODFI. I don't think 2.2.1.2 applies.
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John S. Burnett
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