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#2261724 - 10/27/21 09:00 PM ACH Report of Possible Rules Violation
Irishguy Offline
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Irishguy
Joined: Aug 2008
Posts: 571
Kentucky
What responsibility does a Bank have to report originators that do not act upon NOC files? A cite would be wonderful. Thanks in advance.

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#2261743 - 10/28/21 12:13 PM Re: ACH Report of Possible Rules Violation Irishguy
osucpa Offline
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Joined: May 2011
Posts: 1,398
Try Article Two, Subsection 2.11.1, ODFI and and Originator Action on Notification of Change
and Article Two, Subsection 2.11.2, ODFI Right to Refuse Notification of Change Entries

This information came straight out of our audit program.

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#2261755 - 10/28/21 03:21 PM Re: ACH Report of Possible Rules Violation Irishguy
Irishguy Offline
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Irishguy
Joined: Aug 2008
Posts: 571
Kentucky
I want to make sure I'm explaining and understanding correctly.

Our customer, John Doe, gets a direct deposit from ABC Co. via ACH. When we receive the file, we notice that ABC Co does not have John's correct account number so we submit a NOC and process the transaction because we can determine the account number.

After we submit the NOC, do we have a responsibility to ensure that ABC Co makes the correction within the prescribed time frames? If they don't make the change, do we have to file a Report of Possible Rules Violation?

If Banks do have this responsibility, how do most banks track this kind of information?

Any help would be appreciated.

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#2261762 - 10/28/21 04:19 PM Re: ACH Report of Possible Rules Violation Irishguy
osucpa Offline
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Joined: May 2011
Posts: 1,398
I would tell you if ABC Co. is not your customer you have no responsibility. You hope the information gets changed accordingly. Depending on the size of your bank will depend on how you handle this with your customer. I have seen for small community banks they will reach out to their customer and explain the issue to see if the customer can get it corrected. For larger banks they just process the NOCs.

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