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What Is the New Rule?
While several new ACH Rules are taking effect this year, we’re focusing specifically on the requirements surrounding RDFI ACH Credit Monitoring. This Rule requires RDFIs to establish and implement risk-based processes and procedures to reasonably identify credit ACH Entries initiated due to fraud or authorized under false pretenses.
When Does the Rule Take Effect?
Understanding the implementation timeline is critical to proper preparation. This Rule will be implemented in two phases:
- RDFIs with a 2023 annual ACH receipt volume exceeding 10 million Entries must comply by March 20, 2026.
- All remaining RDFIs must implement the required processes and procedures by June 19, 2026.
What Should You Be Doing to Prepare?
This Rule is intentionally principles-based rather than descriptive, providing a framework that allows financial institutions to tailor their approach based on their unique risk profile and transaction volume.
Key considerations include:
- Developing and formalizing written processes and procedures. These documents not only facilitate staff training and understanding but can also serve as critical documentation during annual ACH Rules compliance audits.
- Implementing a plan to ensure processes and procedures are reviewed at least annually. This is an opportunity for financial institutions to make updates and address evolving risks.
- Collaborating with Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) departments. Evaluate existing processes or products already in place to determine whether they can support ACH credit monitoring requirements.
- Risk-based processes and procedures are not going to require a review of each individual ACH credit Entry. This approach allows RDFIs to use their resources to determine which transactions they decide are an elevated risk and to take additional precautions.
- Applying a true risk-based approach. According to Nacha, though this is a risk-based approach, it cannot be concluded that no monitoring is necessary at all. At a minimum, a risk assessment should be conducted to distinguish higher-risk from lower-risk transactions.
Anomaly detection and velocity monitoring can take many forms. Although this is not a comprehensive list, characteristics to consider include:
- Account type and SEC Code,
- Dollar thresholds or tolerances,
- Name matching and
- Pattern recognition with behavioral tracking.
As the March and June 2026 deadlines approach, financial institutions should prioritize documenting their monitoring processes to meet both Nacha’s and regulatory expectations. While many financial institutions already maintain some level of oversight, these new requirements now require formalizing and documenting those practices. By conducting a thorough risk assessment now and establishing well-defined procedures early, RDFIs can position themselves not only for compliance but for stronger protection against the evolving fraud landscape.
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Here are a few resources and upcoming events:
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