NACHA Operations Bulletin #4-2017
Managing the Risks of C2C Debits
Executive Summary: The NACHA Operating Rules provide for Person-to-Person (P2P) payments via ACH credit transactions. In this way, one person can transfer funds to another person. NACHA has become aware that some financial institutions and their service providers are allowing consumers to debit other consumers’ accounts. This ACH Operations Bulletin1 provides guidance to financial institutions and their service providers on the application of the NACHA Operating Rules and other risk management considerations relevant to the origination of such “consumer-to-other-consumer” (C2C) debits.
Although the origination of C2C debits is not expressly prohibited by the NACHA Operating Rules, NACHA strongly discourages ODFIs from facilitating these payments unless the ODFI is certain of its full compliance with all rules that apply to the origination of all ACH debits, regardless of the nature of the Originator. This should not be read to discourage financial institutions from offering and enabling consumers to transfer funds from their own accounts - i.e., an account-to-account transfer. For such an A2A debit, a consumer has authorized an ODFI or an Originator to debit her/his own account at another institution; and so such a consumer is the Receiver of the A2A debit.
Financial institutions that do not offer, or do not intend to offer, consumer-to-other-consumer debit capability are encouraged to verify that their products, platforms, or service providers are not inadvertently or unintentionally configured to allow this type of transaction.