From your description, Company XYZ will soon be considered both an originator and a third-party sender – an originator for its own transactions and a third-party sender for the other companies’ transactions. Currently, there might be a gap.
In your particular case, it sounds like you should have a contract with each originator. The NACHA Rules are contract-based. You might not have a direct contractual relationship with the originators of many transactions (those where Company XYZ is submitting transactions for other companies). The Rules will be changing to include a “third-party sender” which, in your case if nothing changes, will require Company XYZ to assume more responsibility and stand between you (the ODFI) and the originators. The Rules originally did not anticipate such an arrangement.
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Actually, the Bank is sending through an ACH credit entry to the each of the subsidiary bank accounts at other institutions and to offset the debit entries that are being originated.
Would you mind clarifying this? Is your bank collecting the funds from the various receivers and then forwarding it to the various companies? Or is only one transaction taking place debiting the customers’ accounts and crediting the companies’ accounts? If two transactions are taking place (pull money to an account at your bank, then forwarding funds to the other accounts), you might be taking on unnecessary risk.