a Person that has authorized an ODFI (directly or through a Third-Party Sender) to Transmit, for the account of that Person, a credit Entry, debit Entry, or Non-Monetary Entry to the Receiver's account at the RDFI
Nacha has announced that their System of Fines group will soon resume emailing notices of potential violations to ODFIs who may not have completed the process to register their Third-Party Sender status as required by the Nacha Operating Rules
If you receive these returns back from the ODFI as dishonored returns bearing code R68, Untimely Return, then you should contest the Dishonored Return using code R73, Timely Original Return. If the ODFI contacts you for clarification, you should explain that you are using the Excused Delay provision of the NACHA Operating Rules. You may choose to proactively call the ODFI before sending the original return, but are not obligated under the Rules to do so
Nacha has been incrementally addressing third-party risk management with changes to their Operating Rules and Guidelines over the last five years, and ePayAdvisors has kept pace with services to help Originating Depository Financial Institutions (ODFIs) and their Third-Party Service Providers and Third-Party Senders remain compliant. The Third-Party Sender Registration rule, effective September 2017 with a deadline for initial registration of March 2018, required ODFIs to identify and register their Third-Party Sender customers. The registration process promotes consistent customer due diligence among all ODFIs and serves as a tool to support Nacha’s continuing efforts to maintain ACH Network quality
If you receive these returns back from the ODFI as dishonored returns bearing code R68, Untimely Return, then you should contest the Dishonored Return using code R73, Timely Original Return. If the ODFI contacts you for clarification, you should explain that you are using the Excused Delay provision of the Nacha Operating Rules. You may choose to proactively call the ODFI before sending the original return, but are not obligated under the Rules to do so.
While the Nacha Operating Rules state that the ODFI is responsible for its Originators’ compliance with the Rules, they don’t state specifically how ODFIs should make sure that happens. ODFIs often purchase a copy of the Rules for each Originator and that’s that
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If you receive these returns back from the ODFI as dishonored returns bearing code R68, Untimely Return, then you should contest the Dishonored Return using code R73, Timely Original Return. If the ODFI contacts you for clarification, you should explain that you are using the Excused Delay provision of the Nacha Operating Rules. You may choose to proactively call the ODFI before sending the original return but are not obligated under the Rules to do so
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