Is the bank required to send a pre notification of an ACH or is it mainly a customer service? I know we need ACH signed agreements, but I am not sure about the pre note?

Under NACHA, it is not required to send a pre-notification. This is listed under Section 2.3 of the NACHA rules-"Prior to the initiation of the first entry to a Receiver or a Receiver's account with an RDFI, an originator may, at it's option, deliver or send notification..."

Thank you...I am not very familiar with NACHA and was not sure where to look,

If we get a prenote from an originator or ODFI, we are required to pass it on to our customers...right??

Yes, if we do receive a prenotification, we are obligated to pass it on to the customer.

We have merged banks and therefore routing numbers changed for the banks and this generated pre notes for accounts that already had ACH are we obligated to send these to the customers?

Is the R/T still correct? We had a customer who didn't want to pre-note their ACH debits. One local institution merged with another and the original R/T is now invalid. We have spent way more time on NOC's than the pre-noting would have taken. Our payment association said we can put the pre-note requirement in our contracts and we will from now on because this has been a mess.

We are a RDFI. If I am understanding the thread correctly, if we receive a prenote from an originator we are required to send to our customer for confirmation. How? I am not as familiar with NACHA as I should be. Thank you for your help.

Please see Section III, Chapter I of the Operating Guidelines section of the ACH Rule book. It starts on page OG62. Item # 4 "Response to Prenotification Returns and Notification of Change" states, "There are three ways that an Originator can receive a response to a prenotification. The prenotification can be: returned by the ACH Operator as unprocessable; returned by the RDFI; or result in the origination of a Notification of Change (NOC) from the RDFI." ... "These methods of return and notification of change are addressed completely in Chapter II Notification of Change and Chapter III, Returns, Dishonored Returns, and Contested Dishonored Returns."

Pre-note rules are on page OR5 and OR16 in the Rules section. The way I read Section 4.1.2 on OR16, the RDFI verifies the account number. If there are errors, the RDFI can reject the transaction. If the account number and name do not match, the RDFI can rely solely on the account number for purposes of posting.

I hope this helps.