One thing that never changes about the Nacha Operating Rules and Guidelines is that they’re always changing.
“It’s really a living document. The Nacha Rules are updated, and if you are participating in the ACH Network you need to be aware of current and upcoming rules changes,” said Danita Tyrrell, AAP, APRP, Nacha senior director of ACH Network Rules Development.
Several new rules take effect in 2021 that will impact credit unions, especially in their roles as financial institutions that receive ACH payments on behalf of their members. They include changes related to reversing entries, as well as the timeframe for which a claim can be made that an ACH payment was unauthorized.
“There will also be changes around authorization requirements, which I think is super important for credit unions to be aware of, because if authorizations can have a different look and feel, the credit union needs to be aware of what that look and feel is,” said Tyrrell.
With several new rules are already on track to take effect in 2021, Tyrrell noted, “We are expecting to have more changes to the Nacha Guidelines based around the authorization changes.”
Those are just some of the reasons why credit unions need to have access to the latest version of the Nacha Operating Rules and Guidelines. Not only does the 2021 version contain all of the latest information, “if we issue any supplements to update language in the Rules or in the Guidelines, you will get that for the entire year. It allows the credit union to plan going forward,” said Tyrrell.
“Nacha tends to announce Rules changes that impact the industry with at least a six- to nine-month lead time, sometimes more. When you have a subscription and get those updates, you can plan for what’s upcoming,” she said.
“If you don’t have a current subscription and you are relying on your 2020 book, you’re not going to have the latest. You’ll be missing information,” said Tyrrell. She noted there have been instances where Rules were passed affecting all financial institutions, regardless of size, and “some institutions weren’t aware.”
The Nacha Operating Rules and Guidelines are “the legal foundation of the ACH Network,” with the Rules being a contract between financial institutions and their ACH Operators, said Tyrrell.
“I think that in any instance where I am bound by a legal contract, I would like to have a copy of that contract in my possession, just to be aware of what my rights and responsibilities are with respect to that contract.”