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NACHA Bulletins on International ACH Warranties & High Risk Originators

The Electronic Payments Association (NACHA) recently issued an operations bulletin to narrow the scope of the warranty on outbound IATs to focus solely on the authorization of the entry, when authorization is required by the laws or payment system rules of the receiving country effective on March 15, 2013. Prior to this bulletin, an ODFI of an outbound IAT entry is required to warrant that the IAT entry complies with all the laws and payment systems rules of the receiving country.

On a separate issue, NACHA recently issued an operations bulletin regarding high risk originators and questionable debit activity to address concerns with payday lending transactions on the ACH network. This bulletin is intended to provide guidance to both ODFIs and RDFIs regarding their rights and obligations to help address potentially illicit activity, as well as provide sound practices.