In an effort to enhance the efficiency, clarity and security of International ACH Transactions (IATs), Nacha has issued a Request for Comment (RFC) and Request for Information (RFI) seeking industry feedback on several proposed changes to IAT rules and practices, with responses due by Friday, May 30.
EPCOR will host a free, members-only Special Industry Update webinar on Monday, May 5. This webinar will provide additional context, explain the proposed changes and offer attendees an opportunity to ask questions and share their views. We encourage all members to review the proposed changes carefully and participate in the upcoming webinar. Member input will be critical in shaping EPCOR’s official comment letter to Nacha.
Included in Nacha’s RFC/RFI are several e-commerce marketplace scenarios. We would like to get member feedback on these scenarios. However, due to the number and complexity of the scenarios, we want to allow members ample time to look them over, digest them and react. To gain member feedback, we have put together a Jotform survey. Please provide your feedback via the survey no later than May 9.
All the materials related to Nacha’s RFC and RFI can be accessed via the Knowledge Community.
For a breakdown of the requests from Nacha, keep reading.
Enhancing Understanding and Efficiency of IATs
The RFC includes a series of proposals aimed at improving the ACH Network's ability to detect and respond to fraudulent activity while also making IAT processing more efficient. A key goal of the initiative is to clarify the application of IAT Rules through expanded guidance and updated definitions.
In particular, Nacha is proposing updates to help financial institutions and industry participants more easily determine when a transaction should be classified as an IAT. These updates include ten new example scenarios focused on transactions involving online marketplaces.
Overview of Proposed Rule Changes
Nacha's proposed modifications include seven key rule updates:
- Simplifying the Definition of IAT Entries – Making the criteria for IAT designation more straightforward and easier to apply.
- Enabling Same-Day Processing for IAT Entries – Improving the speed and efficiency of international transactions.
- Adding an Optional Date of Birth Field – Providing additional data that may help in identifying individuals and managing exceptions.
- Permitting Outbound IATs to Non-Bank Financial Agencies – Expanding the range of eligible recipients.
- Requiring IAT Contact Registration in Nacha’s ACH Contact Registry – Ensuring institutions have clear points of contact for IAT-related issues.
- Establishing Standards for Valid Characters in IAT and ACH Records – Promoting consistency and reliability in data formatting.
- Introducing a New Return Reason Code (R90) – Allowing entries to be returned under Office of Foreign Assets Control (OFAC) instruction.
These proposals are designed not only to reduce fraud but also to improve the ability to recover funds in the event of unauthorized or erroneous transactions.
Request for Information on Future Rule Considerations
In addition to the formal rule proposals, Nacha is seeking industry input on four emerging areas that could shape future rules:
- Enhancing the quality and consistency of data in IAT entries.
- Assessing the need for additional IAT Addenda Records to support complex transaction types.
- Evaluating the demand for new IAT Transaction Codes or Indicators to improve classification.
- Improving communication of IAT-related changes via Notifications of Change (NOCs) and return entries.
While these topics are not part of the current rulemaking process, industry feedback could lead to future proposals.
Industry Engagement and Webinar Opportunity
To support member participation, EPCOR will host a free, members-only Special Industry Update webinar on Monday, May 5 at 10 a.m. CT / 11 a.m. ET. This session will provide additional context, explain the proposed changes, and offer attendees an opportunity to ask questions and share their views.
All responses to the RFC and RFI are due by Friday, May 30, 2025.
EPCOR encourages its members to review the proposed changes carefully and participate in the upcoming webinar. Member input will be critical in shaping EPCOR’s official comment letter to Nacha.