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Start with Thorough Due Diligence
The foundation of any strong ODFI-Originator relationship is comprehensive due diligence. Before onboarding, it's crucial to understand an Originator’s business model, processing history and overall financial health. This initial deep dive ensures that you are partnering with a reputable organization and helps anticipate their needs and potential risks from the outset.
Educate to Empower and Prevent Fraud
Fraud prevention is a shared responsibility. One of the most valuable services you can provide as an ODFI is educating Originators on current fraud trends, scams and best practices for securing their systems. Proactively providing resources and training can significantly reduce the likelihood of costly incidents. For accessible educational materials, consider resources like our Corporate User Page, designed to help corporate users understand their roles and responsibilities within the ACH Network.
With new ACH fraud monitoring rules taking effect in 2026, education is becoming even more critical. Beginning in March 2026, high-volume non-consumer Originators will be required to implement risk-based fraud monitoring processes, with all other non-consumer Originators, Third-Party Senders and Third-Party Service Providers phased in by June 2026. To help Originators understand their expanding role as the first line of defense in the ACH Network, EPCOR offers the Fraud Monitoring Rules for ACH Originators toolkit, which includes ready-to-share social media content, article copy, ad messaging and other resources designed to support compliance and fraud prevention efforts.
Set Realistic and Commensurate Exposure Limits
Exposure limits are more than just a compliance checkbox — they’re a vital risk management tool. Ensure that an Originator's exposure limits reflect their actual business activity and financial standing. Regularly reviewing these limits to accommodate growth while protecting your institution demonstrates attentiveness and a commitment to responsible support.
Ensure Agreements are Current and Comprehensive
A well-executed agreement defines roles, responsibilities and liabilities. Regularly reviewing Originator agreements ensures they remain up to date with the latest ACH Rules, include all applicable Appendix C items and contain proper authorization language. EPCOR members looking for a solid template can explore our Sample ODFI-Originator ACH Origination Agreement, which offers a compliant and customizable starting point.
Build a Partnership, Not Just a Process
Beyond contracts and compliance checks, remember that you are building genuine relationships. Take the time to understand your Originators' challenges, goals and their business evolution to transform transactional relationships into long-term partnerships. Collaborative engagement fosters loyalty while keeping risk at manageable levels.
Commitment and Consistency
Just as a New Year’s resolution requires dedication and a solid routine, strengthening an ODFI Risk Management Program necessitates a disciplined approach. Think of your documented due diligence process as your organization’s “workout plan” — it needs to be consistent and thorough for both new and existing Originators.
A strong program regimen should include:
- A Warm-Up: Onboarding new ACH clients.
- Limits: Defining exposure limits.
- Regular Weigh-Ins: Scheduling periodic reviews.
- Foods to Avoid: Identifying prohibited business types.
- Approved Exercises: Implementing authorized Standard Entry Class (SEC) Codes.
- Progress Tracking: Ongoing monitoring of activity and returns.
Keeping this “fitness plan” in motion helps your financial institution build compliance strength, manage risk effectively and maintain your ODFI as a trusted partner in the ACH Network.
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