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To remain in compliance with the Rules, participants in the ACH network need to ensure they are up to date on recent changes and newly approved amendments to the Rules. 

The Risk Management topics will improve recovery of funds in fraud situations (after the Frauds have occurred), there are two phases - Phase 1 outlines everything as part of the Risk management package including the threshold for the first group of participants that need to comply. Phase 2 outlines the participants that did not meet the first threshold - and their obligation to meet these Risk Management Rule amendments. These are a NEED to KNOW! Your ACH Risk process is changing for BOTH the ODFI and RDFI! Register Today to ensure YOUR compliance with the NEWEST UPCOMING (2026) updates to the Nacha Operating Rules!!
 


  • Fraud Monitoring - for ODFI, Originators, TPSP and TPS PLUS Credit Monitoring - for RDFI (Phase 1) 
  • Describe which participant is affected and what parts of the Rule applies to whom and outlining the threshold limits for each
  • Define what’s changing with "commercially reasonable fraud detection system"
    Provide details on the next level description of requirements - i.e., "reasonably intended to identify" (including the requirements that apply "to the extent relevant to the role the entity plays")
  • Outline how the Rule allows an ODFI to expressly consider steps other participants in origination are taking to monitor for fraud
    List other parts of the Rule relating to monitoring
  • Identify the requirement of an "at least annual" review of processes and procedures
  • Standardization of Company Entry Descriptions
  • Describe "when" to use the NEW "PAYROLL" and "PURCHASE" as the NEW Company Entry Descriptions
  • Identify the IMPACTS and BENEFITS to the participants involved in this change to formatting
  • Fraud Monitoring - by Originators, TPSP and TPS PLUS Credit Monitoring - for RDFI (Phase 2)
  • Define which participants are affected and what parts of the Rule applies to whom (the parties who didn’t meet the first threshold)
  • Examples used throughout the presentation will help identify the “meaning” of these new Nacha Operating Rule amendments

Each participant in the ACH Network is required to follow the Nacha Operating Rules and be compliant, even when it pertains to Risk.  
Effective March 20, 2026 – Phase 1 for Risk Management (part of a larger package) to help reduce the incidence of successful fraud attempts and improve recovery of funds:
  • Fraud Monitoring by Originators, Third-Party Service Providers/Third Party Senders and ODFIs
  • ACH Credit Monitoring by RDFIs
  • Effective March 20, 2026 – Standardization of Company Entry Descriptions (also part of Risk Management)
  • Standardizing the use of Company Entry Description can help participants in the ACH Network, to identify, monitor and count the volume of payments for specific purposes; (thus helping to manage ACH Risk)
  • The two new defined Company Entry Descriptions PAYROLL and PURCHASE (all UPPER Case)
 
PLUS Effective on June 19, 2026 - Phase 2 for Risk Management a continued part of a larger Risk Management package (Rules Changes) to help reduce the incidence of successful fraud attempts and improve the recovery of funds. 
Included in this portion of Risk Management Rule amendments are:
  • Fraud Monitoring by Originators, Third-Party Service Providers/Third Party Senders and ODFIs (for all non-Consumer Originators, TPSPs, and TPSs that did not fall under the requirement threshold for Phase 1)
  • ACH Credit Monitoring by RDFIs (for all RDFIs that did not meet the threshold requirement for Phase 1)

  • Financial Institution Professionals (New/Current Ops Staff)
  • Third-Party Processors
  • Originating Companies
  • Banking Operations Managers and Staff
  • Compliance and Risk Professionals
  • Treasury Management Professionals
  • Aspiring and Current AAPs (Accredited ACH Professionals)
  • Banking Managers/ Supervisors
  • Audit and Compliance Personnel / Risk Managers

Donna K Olheiser, AAP, is the vice president of Education Services and founder of Dynamic Mastership, LLC. Donna is an enthusiastic and energetic Certified Master Trainer with over 14 years’ training experience. She has designed and facilitated over 100 training sessions each year with her expertise being the rules for companies and financial institutions when processing specifically ACH electronic payments, then scheduling the training events to facilitate/deliver the material through a variety of venues (webinars, teleseminars, in-person workshops, including regional and national conferences). Donna has over 24 years of experience in the financial services industry which includes 9 years’ experience as the education service director at a Regional Payments Association (RPA), where she managed and facilitated the entire education program for nearly 800 financial institution members. Prior to that, Ms. Olheiser spent 14 years in various departments with the Federal Reserve Bank of Minneapolis and also holds the Accredited ACH Professional (AAP) designation (achieved in 2004).

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