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Mark your calendar: Third-Party Sender roles and responsibilities effective September 30

Effective September 30, 2022, Nacha will add two rules clearly defining roles and responsibilities for Nested Third-Party Senders and the Third-Party Senders Risk Assessment. Both rules allow for a six-month grace period. Specifics are detailed in Nacha’s Third-Party Sender Roles and Responsibilities (Off-site) ruling.

The first rule will include:

  • Definition of a Nested Third-Party Sender (TPS)
  • Origination Agreement update requirements for a Nested TPS relationship
  • How to establish the chain of agreements and responsibilities within a Nested TPS relationship
  • Update TPS registration to determine existence of a Nested TPS relationship

The second rule requires TPSs to complete and conduct their own ACH activity Risk Assessments.

For additional information on either rule, please visit Third-Party Sender Roles and Responsibilities (Off-site).