ePayAdvisors | Third-Party

Third-Party Sender & Service Provider ACH Compliance Audit

Have you completed your required ACH Compliance Audit?

Is your organization in compliance with the Nacha requirement that all Third-Party Service Providers and Third-Party Senders that have agreement with a Participating DFI to process Entries conduct an annual audit of compliance with the Nacha Operating Rules? 

Article One, Subsection 1.2.2 Audits of Rules Compliance of the Nacha Operating Rules states:

A Participating DFI must annually conduct, or have conducted, an audit of its compliance with these Rules. A Third-Party Service Provider or a Third-Party Sender that has agreed with a Participating DFI to process Entries must annually conduct, or have conducted, an audit of its compliance with these Rules. An annual audit must be conducted under these Rules Compliance Audit Requirements no later than December 31 of each year.

Experienced, accredited payments experts can perform your ACH Risk Compliance at a competitive rate! The scope of our audit is continually enhanced and is based on the ACH Rules identified in Article One, Article Two, and Appendix Three of the Nacha Operating Rules. We also assess the efficiency and effectiveness of written policies and procedures as well as adherence to OFAC screening requirements.

At the conclusion of your ACH Compliance Audit, we provide you with:

  • an informative, detailed report identifying areas of compliance deficiencies; 
  • a summary of all findings; and 
  • recommended improvement opportunities to reduce risks.

Article 8 of the NACHA Operating Rules Defines the Definitions and Terms used in the Rules

SECTION 8.110 “Third-Party Sender”

a type of Third-Party Service Provider that acts as an intermediary in Transmitting Entries between an Originator and an ODFI, including through Direct Access, and acts on behalf of an Originator or another Third-Party Sender. A Third-Party Sender must have an Origination Agreement with the ODFI of the Entry. A Third-Party Sender is never the Originator for Entries it Transmits on behalf of another Organization. However, a Third- Party Sender of Entries may also be an Originator of other Entries in its own right.


SECTION 8.111 “Third-Party Service Provider”

an Organization that performs any functions on behalf of the Originator, the Third-Party Sender, the ODFI, or the RDFI (not including the Originator, ODFI, or RDFI acting in such capacity for such Entries) related to the processing of Entries, including the creation of the Files or acting as a Sending Point or Receiving Point on behalf of a Participating DFI. An Organization acting as Third- Party Sender also is a Third-Party Service Provider.

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