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Nacha Issues Request for Comment and Request for Information

Request for Comment on Third-Party Sender Roles and Responsibilities; Responses Requested by July 1, 2021

Nacha is seeking comment and feedback from industry stakeholders on two related Rules proposals collectively referred to as “Third-Party Sender Roles and Responsibilities.”  The overarching purpose of these proposals is to further clarify the roles and responsibilities of Third-Party Senders in the ACH Network by: 1) addressing the commercially existing practice of Nested Third-Party Sender relationships; and 2) making explicit and clarifying the requirement that a TPS conduct a Risk Assessment.  Comments are due by Thursday, July 1, 2021. 

Request for Information on Risks of Early Funds Availability; Responses Requested by July 16, 2021

Nacha is seeking industry comment and feedback (Request for Information) on whether a Rules proposal should be developed to adjust the allocation of risk when RDFIs make funds from ACH credits available early, before the settlement date of the ACH credit.  A Request for Information is not a proposal to amend the Nacha Rules.  In this case, the purposes of the RFI are to raise awareness of the issue and its risks, and to start industry thinking and dialogue on whether a Rules proposal should be considered or pursued.  Comments may be provided through the industry questionnaire or by comment letter. Responses are requested by Friday, July 16, 2021. 

Documentation and Comment Process

Nacha encourages responses from ACH Network participants and other interested parties.  For more information about how to submit comments, please visit

The Request for Comment consists of three documents:

A Rules Proposal description presentation as a PDF;

An ACH participant survey – this is a Word version of the online survey, which will be available soon via the Nacha web site at  To enable respondents to gather information from within their organizations, the survey questions are provided as a Word file to the Nacha family attached to this e-mail.  Please review the survey questions prior to beginning your response so that you can gather information and comments from all impacted areas of your organization before responding to the questions.

Proposed modifications to the Nacha Operating Rules as a PDF.  These are the proposed changes to the language of the Nacha Operating Rules.  All proposed modifications are highlighted in yellow, with text proposed to be added shown in yellow underline, and text proposed to be deleted shown in yellow strikethrough.

The Request for Information consists of two documents:

Return comments to:  
Maribel Bondoc, Manager, Network Rules
Fax: (703) 787-0996

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