Real Time Payments NACHA Rules

From the Real Time Payments NACHA Rules

Foreign Payments. The RTP System shall be used by Participants only to effectuate RTP
Payments between a Sender and Receiver whose Accounts are located in the United
States of America. To the extent a Sender sends or a Receiver receives a Payment on
behalf of another Person, whether such Sender or Receiver is a Payment Service
Provider or not, the Person on whose behalf the Sender sends or the Receiver receives
must be a resident of or otherwise domiciled in the United States. Participants must
inform Senders and Receivers of their obligation to comply with this restriction
regarding Payments sent or received on behalf of other Persons and with OFAC
regulations in the legal terms that govern their Customers’ use of RTP.

Are there any consumer disclosure requirements? If so this is the first I have heard of this, but I'm not necessarily a NACHA expert. Any guidance would be appreciated. Thanks.

RTP is a separate payment rail from ACH, I am not aware that Nacha has published any RTP Rules. EPN/The Clearing House and FRB FedNow is probably what you should be looking at.

Perhaps I misquoted the source that I quoted - we got this from The Clearing House

https://mc-e3a82812-8e7a-44d9-956f-...mp;hash=502D59B5AB389397960EC42F14A47BC4

Just attempting to determine whether or not as a receiver bank whether we need to provide some type of customer disclosure.

Any advice or point in the right direction would be appreciated.

Banks already have this in their Depositor's Agreements - here is US Bank's:

REAL-TIME PAYMENTS / PROHIBITION ON FOREIGN PAYMENTS
Real-Time Payments (“RTP”) is an electronic payment system which permits payment senders to send funds in real-time to payment receivers for deposit into the payment receiver’s account(s). This means that a payment receiver will have near immediate availability of funds sent using an RTP system. The RTP system is intended for domestic payments only. It prohibits payments which involve either a sender or receiver located outside the United States. You agree that to the extent you either send or receive payments through an RTP system, you will not use your accounts to do so on behalf of a person who is not a United States resident or otherwise domiciled in the United States and that you will comply with all regulations of the Office of Foreign Assets Control.