Help! I think I'm losing my mind. I'm auditing ACH and corporate originators are given access to Shazam software. The corporate customers then send their ACH files directly to Shazam for them to process. As the ODFI, shouldn't we have copies of the individual ACH files that were originated. Per the NACHA Operating Rules, Section 1.5, Records, Subsection 1.5.1, Records of Entries, each participating DFI must maintain records of all entries, including return and adjustment entries, it transmitted to or from an ACH Operator. Since the ODFI is ultimately responsible for its Originators shouldn't the Bank have copies of the files. Any input or guidance is appreciated

So is Shazam acting as your Third Party Processor? Is there a contract between your bank and Shazam?

yes there is a contract between the bank and Shazam. It is my understanding that Shazam is the ACH Operator and a not a Third Party provide but maybe they are one in the same.