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Once upon the daylight dreary, after I was defrauded, weak and weary,
Over many a quaint and curious ACH volume of forgotten lore.
While I nodded, nearly napping, suddenly there was a tapping,
As if someone gently rapping, rapping at my financial institution’s door.
“Tis new ACH Rules”, Nacha muttered, tapping at my chamber door.
“Only our new ACH Rules and nothing more”
Ah, distinctly I remember it was a bleak March 2024,
And each ACH fraud type wrought its wrath upon my store.
Eagerly I wished it was tomorrow, as each fraud type brought no sorrow.
From the many fraud tips that I borrowed, I could not get my ACH Originators to explore,
Just putting forth a little more time and effort for fraud techniques they ignored.
Fraud seemed to be here evermore.
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And the fine folks from Nacha presented new 2026 ACH Rules to assure,
Thrilled me, filled me with fantastic hope that I never felt before.
So that now, to still the beating of my heart, I stood repeating:
“’Tis new ACH Rules entreating entrance at my financial institution’s door,
And bringing forth new rules or risk-based procedures and processes rules to adore”
“This is it and nothing more”
Presently, my soul grew stronger, hesitating and then no longer.
“ACH Originator”, said I, “truly your forgiveness I implore”
“But for 2026, we’re going to explore what you have in your drawer
To help reduce ACH fraud nevermore!”
And then you came tapping, tapping at my chamber door.
“What should we do to combat fraud”, the Originator asked as I opened wide the door
Establish and implement risk-based processes and procedures, and nothing more.
Deep into our meeting room that curiosity was peering, long I stood there wondering, fearing,
Doubting how this new rule would be accepted by Originators who often rejected.
But the silence was unbroken, because this time the ACH Rules have spoken.
And the only word spoken was the whispered word “More”?
Then I whispered, an echo murmured back the word “You’ll have to do more”.
Merely this and nothing more.
Back in the meeting room turning, all my soul within me churning,
Soon again I heard a tapping somewhat louder than before.
These new ACH Rules are to protect points of transmissions and authorizations,
So let us see, then, what thereat is, and this mystery to explore
On how you could strengthen your processes to avoid fraud rather than to ignore.
“Tis the documented procedures and so much more”
Open here I began to stutter, when, with many a flirt and a flutter,
In here stepped ideas of how to improve controls to cause confidence to be restored.
Not just creating processes or procedures but what is practical for the Originator,
To help mitigate the risk of fraudulent payment instructions coming to their door,
Perched upon them were fraudsters with phony emails and scams galore.
Perched and sat, waiting for the Originator to be lured.
The fraudster was beguilding my sad fancy into a trap,
Trying to convince me that an existing Receiver’s account info had been scrapped.
“These are my new account instructions”, the email said, “we switched institutions”
Said the fraudster, laughing in his dark room far away, playing the Originator like a musician.
Ghastly grim, the ACH Originator wondered why account information suddenly changed
From a Receiver who seemed loyal to their institution to suddenly become estranged.
And the fraudster was hoping the account information would be exchanged.
Much as the Originator marveled this ungainly email to hear discourse so plainly,
That a phone call to the Receiver’s longtime contact number would help explore,
Why someone so loyal would instantly switch institutions and communicate it like never before,
For we cannot help that maybe we or they are getting scammed once more,
As emails are easily hacked or intercepted which cannot be underscored,
And these scams and schemes won’t stop until the fraudster says “nevermore”.
Startled by the phone call to the Receiver, the Originator baffled,
How could we fall for a scheme as if our payments were given away by a raffle?
Soon, again, the Originator heard a tapping somewhat louder than before.
“Surely”, said the Originator, “we can implement something to improve us at our core”
“Something that improves our due diligence and account info of our receivers to assure”,
“That the fraudsters won’t be any issue anymore”
Improving the point of transmission or the authorization process, evermore.
Then the ODFI engaged in guessing, but no syllable expressing,
To how they’ll ensure that the Originator’s risk-based processes and procedures are impressing.
Then, upon my chamber door came more tapping, as it was Nacha who was rapping.
That this is a new rule and ODFI’s existing ACH agreement already has the tools.
Originators must agree to be bound by ACH Rules and that is the jewel,
Which the ODFI may use to audit, suspend, or terminate an Originator who finds that uncool.
But if an auditing ODFI arrives at an Originator’s door, they’ll have to implore.
Fraud keeps growing because taking extra time to verify information feels like a chore,
But growing fraud statistics show that fraudsters are winning the score.
Yet, with a little more time and attention towards your procedures and processes like never before,
Could help push back on fraud and forever help slam the door,
On ACH fraudsters who think they can say “evermore”
The many losses taken have been a painpoint to a bank or a store,
As it’s time for ODFIs and Originators to tell fraud “nevermore”.