Over the last several months I have received several questions regarding “Is this a Third-Party Sender or a Third-Party Service Provider”? And more specifically the confusion seems to be about payroll processors that use their clients online banking accounts to originate ACH files. The simplest way that I have found to identify these relationships is to look to who has the ACH Origination Agreement and the account with the ODFI. In the above scenario the payroll provider does not have the Agreement or the account with the ODFI but rather their clients do therefore the payroll processors are Third-Party Service Providers.
Another useful resource I have found to help analyze and identify Third-Party Senders is the NACHA ACH Operations Bulletin #2-2014 entitled “ACH Transactions Involving Third-Party Senders and Other Payment Intermediaries” which was released on December 30, 2014. The Bulletin details several ACH processing scenarios using flowcharts and the bulletin does a good job explaining what to look for when trying to identify a Third-Party Sender.
Kimberly Martin, Director, Third-Party Services
EPCOR