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#1336900 - 02/03/10 07:38 PM ACH Ammendment Changes
jlsmith Offline
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Can someone give me an idea about what is changing in the ACH realm? We've already established policies and procedures for IAT transactions. Is there more to it?

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Deposits and Payments
#1337489 - 02/04/10 04:23 PM Re: ACH Ammendment Changes jlsmith
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EFFECTIVE MARCH 19, 2010

Authorization and Returns
Revises the Rules to refine the requirements for obtaining a Receiverís authorization for an ACH payment and modify the processes by which RDFIs handle Receiversí claims of unauthorized debits. Specifically, this amendment (1) clarifies the requirements for authorization of ACH entries, adopting the language of Regulation E that an authorization must be ďclear and readily understandable;Ē (2) clarifies that a purported authorization that is not clear and readily understandable is not considered a valid authorization; (3) eliminates the requirement that a Receiverís written statement regarding an unauthorized debit be made under penalty of perjury; (4) establishes minimum information requirements for and revises timing requirements related to the written statement; and (5) expands the use of R39 for duplicate check/check conversion payments.

Stop Payments and Regulation E
Revises specific language within the Rules regarding the application and expiration of a stop payment order. As the Federal Reserve Boardís Staff Interpretation of Regulation E has changed over time, there has been a divergence between the Rules and Reg E with respect to the intent of, and processing requirements for, stop payment orders on ACH debits. These differences have become significant enough to result in the potential for RDFIs to have difficulty reconciling their obligations under both the Rules and Reg E. This amendment re-aligns the Rules with the requirements of the Federal Reserve Boardís Regulation E.

EFFECTIVE JUNE 18, 2010

Direct Access Registration
Modifies the Rules to require (1) ODFIs to register their Direct Access status with NACHA; (2) ODFIs with Direct Access debit origination relationships to provide NACHA with specific information about each Originator or third-party with such a relationship; and (3) an ODFIís board, committee of the board, or the boardís designee to approve a Direct Access Debit Participant prior to the ODFI originating ACH debit entries for the Originator or third-party.

Risk Management and Assessment
Updates the Rules to codify additional risk management practices regarding (1) the performance of due diligence with respect to Originators and Third-Party Senders; (2) the assessment of the nature of the Originatorís or Third-Party Senderís ACH activity and the risks it presents; and (3) the establishment of procedures to monitor an Originatorís or a Third-Party Senderís origination and return activity, and to enforce exposure limits and restrictions on the types of ACH transactions that may be originated.
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#1337744 - 02/04/10 07:19 PM Re: ACH Ammendment Changes 'Lil Freak!
jlsmith Offline
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Right now, we charge $30.00 for a stop payment order. It is only good for one hit. Does the new regulation require banks to stop the item permanently if the customer requests?

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#1337837 - 02/04/10 08:07 PM Re: ACH Ammendment Changes jlsmith
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The consumer may place a stop payment on a one-time or recurring debit. A consumerís right to stop payment of pre-authorized electronic debits applies to all future debits from a specific Originator if that is the consumerís intent, and that the financial institution must make arrangements so that no future debits are posted to the consumerís account. The stop payment order no longer expires after six months, but stays on indefinitely.
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#1337915 - 02/04/10 09:08 PM Re: ACH Ammendment Changes 'Lil Freak!
jlsmith Offline
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Thank you for the clarification!

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#1339456 - 02/08/10 04:49 PM Re: ACH Ammendment Changes jlsmith
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Hey, Freak. Do you have a link to where this rule change is available on the Internet? smile

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#1339572 - 02/08/10 06:44 PM Re: ACH Ammendment Changes buggs
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www.achrulesonline.org

However, you'll need the serial number printed on the inside cover of your 2010 ACH manual.
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#1339609 - 02/08/10 07:18 PM Re: ACH Ammendment Changes 'Lil Freak!
buggs Offline
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Thanks. I was able to locate our book and get access. smile

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#1347276 - 02/22/10 10:44 PM Re: ACH Ammendment Changes buggs
morirse de risa Offline
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Do one-time debits also have the "indefinite" stop payment time frame, or can we still place those on the system to expire after 6 months?

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#1347309 - 02/23/10 12:58 AM Re: ACH Ammendment Changes morirse de risa
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This is very helpful too.

http://admin.nacha.org/userfiles/File/ACH_rules/Jan1310%20telelseminar%20questions%20-%20_jan%2029,%202010_.pdf
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#1347472 - 02/23/10 03:23 PM Re: ACH Ammendment Changes DD Regs
morirse de risa Offline
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Excellent resource, thank-you.


Just curious if other banks use the same stop payment form for both checks and ACH items?

Will you continue to do so even though check stop payments expire after 6 months and ACH items do not?

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#1347565 - 02/23/10 05:10 PM Re: ACH Ammendment Changes morirse de risa
Nancyod Offline
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We have decided to stick with one form.

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#1351269 - 03/02/10 09:10 PM Re: ACH Ammendment Changes Nancyod
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Does your form have the stop will expire in 6 month language on it? If so, how will you not apply this to ACH holds?
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#1351327 - 03/02/10 10:39 PM Re: ACH Ammendment Changes DD Regs
cccgirl Offline
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We are going to use two forms because of the 6 month language, but what about stops on paper transactions converted to ACH? We plan to use the check stop payment form for these, but will we be out of compliance if it later gets converted and the stop has dropped off?

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#1351359 - 03/03/10 01:11 AM Re: ACH Ammendment Changes cccgirl
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That is a thought I had earlier. We are considering not expiring any stops.
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#1351446 - 03/03/10 02:29 PM Re: ACH Ammendment Changes DD Regs
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Do you DP system limits, the system will only allow one default setting, either all expire in 6 months or no expiration. If we go the 6 month expire rout, we can set up a system report that tells us when stops are expiring then renew the ACH ones for 6 more months, but his seems like a rather manual process.
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