Third-Party Sender Services and Resources
Due to increased regulatory attention and compliance requirements directed toward Third-Party relationships EPCOR to offers the following specific, dedicated resources to aid Third-Party Senders and their ODFIs in understanding and meeting their risk and compliance obligations:
Third-Party Senders: Are You In Compliance?
If you answer NO to any of these questions, it may be time to contact EPCOR:
- Have you conducted your required annual ACH Rules Compliance Audit?
- Have you recently conducted your periodic risk assessment?
- Does your service agreement with your merchants include references to the ACH Rules?
- Are you monitoring the ACH return rates of your merchants by return reason code?
- Have you refreshed the due diligence on your merchants this year?
ODFIs: Are You In Compliance?
If you answer NO to any of these questions, you too should consider contacting EPCOR:
- Have you identified your Third-Party Sender Originators? Have you looked at small CPA firms? Payroll Processing companies? Property Management Firms?
- Have your Third-Party Senders completed their required annual ACH Rules Compliance Audit and an ACH Risk Assessment?
- Have you registered your Third-Party Senders with Nacha?
- Have you refreshed the due diligence on your Third-Party Senders this year?
- Do all of your Third-Party Senders have exposure limits assigned to them?
- Do you know whether any of your Third-Party Senders also have Third-Party Sender customers (Nested Third Parties)?
To learn more about Third-Party Sender compliance and EPCOR’s Third-Party Sender Services, contact Amy Donaghue.
Third-Party Sender Registration
On September 2017 the Third-Sender Registration ACH Rule went into effect. This Rule requires all ODFIs to register with Nacha, those Third-Party Senders whom they originate for. This is a big step in recognizing Third-Party Senders for what they are, valuable and trusted members of the electronic payments ecosystem.
Nacha’s website states "The registration process will promote consistent customer due diligence among all ODFIs, and serve as a tool to support Nacha's continuing efforts to maintain ACH Network quality."
Initial registration consists of information that the ODFI should already be in possession of. This is:
- The ODFI and company contact information
- The name and principle business location of the Third-Party Sender
- The ODFI routing number used to originate ACH transactions
- The Company ID of the Third-Party Sender
Not only must ODFI’s register their principle Third-Party Senders, but they must also register any of that Third-Party Sender’s customers who are also Third-Party Senders (nested Third-Party Senders).
The registration process can be completed online at the Nacha Risk Management Portal. Tutorials on registering your TPS can be located on the Nacha and EPCOR websites.
The first step in compliance with this new ACH Rule is properly identifying Third-Party Sender relationships.
What does a Third-Party Sender look like?
Nacha’s Third-Party Sender Identification Tool is designed to assist ODFIs in identifying Third Party Sender relationships, such as Payroll Companies, CPA Firms and Property Management Firms to name a few.
EPCOR is also available to assist you with identifying these relationships. In addition to educational offerings, our Third-Party Services can provide on-site assistance as needed.
To find out more, contact Amy Donaghue.
Want to learn more?
If you would like to learn more about Nacha’s Third-Party Sender Registration Rule, consider registering for one of the following learning events:
A Special Forum for Third-Party Senders and ODFIs
The EPCOR Third-Party Sender Forum is now called the TPS/ODFI Roundtable. This forum is open to all EPCOR Associate members and EPCOR ODFIs that originate for Third-Party Senders to allow for a unique space to collaborate on issues important to Third-Party payment processing. It is intended as a opportunity to discuss best practices and voice industry concerns in a friendly safe environment. The Roundtable meets once a month by teleconference. Those interested in learning more about the Roundtable should contact Amy Donaghue.
Third-Party ACH Audit Service
The Nacha Operating Rules require all participating depository financial institutions, Third-Party Service Providers and Third-Party Senders to conduct an annual ACH Rules Compliance Audit. We customize our ACH Rules Compliance Audits for a variety of Third-Party Service Providers and Third-Party Senders to ensure a comprehensive review of your unique processing environment.
Third-Party ACH Risk Assessment Service
The Nacha Operating Rules require all participating depository financial institutions, Third-Party Service Providers and Third-Party Senders to conduct a periodic ACH Risk Assessment. We tailor our ACH Risk Assessments for each organization to ensure that risks related to Third-Party Service Providers and Third-Party Senders understand the risks related to ACH origination and have a strong internal control structure in place to appropriately mitigate risks.
Third-Party ACH Consulting Services
Designed to assist Third-Party Service providers and Third-Party Senders after completion of their annual ACH Rules Compliance Audit, the consult is a comprehensive review of current processes coupled with recommendations for improved compliance with the ACH Rules. We assist your organization in designing and implementing ACH compliance procedures and provide tools and resources to assist in your on-going business needs.