As a Financial Institution, a Third-Party Service Provider (TPSP) or a Third-Party Sender (TPS), processing ACH transactions, you can encounter a variety of risks. Risk DOES exist in the ACH Payment System, as it does in all payment systems. The risks that need to be examined are Operational, Credit, Compliance, Fraud, Return, and Reputational Risk. According to the Nacha Operating Rules, financial institutions are required to assess and manage all ACH risks, which includes developing a Risk Management program. Most ACH risk can be mitigated through proper due diligence for all originating customers and strict adherence to ACH origination and credit policies, which includes monitoring ACH activity.
A recent Nacha Operating Rules amendment addresses TPS and “nested” TPS (effective Sept 2022), identifying the existence of TPS (and nested TPS) that requires an ACH Risk Assessment be performed for ALL Third-Party Senders (nested or not). In addition, the Rules amendment includes the ODFI’s obligation with agreements with TPS and their “nested” TPS. Details on the responsibility for the ODFI regarding the TPS registration requirement to include the “nested” TPS and how to get this done to remain compliant with this change.
Why Should You Attend:
This virtual 2-day seminar/workshop will identify the areas of ACH Risk that ODFI's and RDFI's are exposed to when originating, receiving, or processing ACH transactions. ACH Risk awareness and responsibility still falls on the ODFI even when outsourcing these activities to a third party. Discussion on ODFI Risk Management Requirements from the Nacha Operating Rules Book (Articles 1 and 2) such as due diligence, exposure limits, auditing, and monitoring (to name a few), plus how the SEC Code being used by the Originator or TPSP or TPS determines specific risk management requirements and warranties.
Included with this ACH Risk Assessment seminar/workshop will be the details for the TPS and “nested” TPS conducting their ACH Risk Assessment due to the recent update to the Nacha Operating Rules with “Third-Party Sender (TPS) Roles and Responsibilities”, effective Sept 2022.
During this 2-day event, participants will participate in a hands-on activity (using provided worksheets) participating in "assessing the risk" of fictitious companies and third parties to help identify the importance of due diligence (KYC-Know Your Customer), including setting and enforcing exposure limits.
As a financial institution, your ACH Policies on Origination and Receipt of ACH Entries is a big part of helping to manage your ACH Risk. As part of the Nacha Operating Rules, the exposure limits (being set and enforced) should be appropriate based on the risks of each customer (the Originator). By assessing the risk with each Originator and identifying potential companies who may require additional measures to help reduce the risk they bring based on the type of business they are in and/or the type of transactions they are sending.
In addition to the Nacha Operating Rules, Financial Institutions should utilize guidance provided by FinCEN, the FFIEC and the OCC to develop an ACH Risk Management program that reflects the nature and complexity of their activities. This workshop will identify this guidance issued and provide resources for effectively managing ACH Risk in the future.
Details on the Nacha Operating Rules for conducting an ACH Risk Assessment and developing an effective Risk Management Program for the participants in the Network who are required to perform this task will be covered. The trainer will outline the key components of an effective ACH Risk management Program while participating in a fictitious scenario and developing that program. ACH Policies and the importance of them, reporting to the Board regarding your ACH program, and registration requirements with Third-Party Senders (according to Nacha) for the ODFI will be included. In addition, the details for the NEW Nacha Rule Amendment on “TPS – Roles & Responsibilities” – effective Sept 2022.
This virtual seminar/workshop (via webinar over two days) will be an adventure for all who attend as we assess the risk based on individual companies and the business they are in and then develop an ACH Risk Management Program during a fictitious scenario (this will help outline the key elements of managing ACH Risk).
Register today! A "must-attend" 2-day virtual seminar/workshop!
In-Person Seminar going Virtual with increased learner satisfaction.
Yes, attend this seminar from anywhere. We are making it real and more interactive – Here's a sneak peek:Our enhanced delivery process and technology provides you an immersive experience and will allow you to access:
- The real-time and live presentation as in in-person events
- Private chat for company-specific conversation – the same as you would get in an in-person seminar
- Opportunities to connect with your peers to share knowledge at a different time and have group discussions
- Live workshop activities
- Live Q&A during the event and offline Q&A assistance after the event
- As usual more content, activities and case studies and now adding homework for a comprehensive understanding
- Certification
Learning Objectives:
- Discover how the ACH Network functions (overview of ACH, how it works, with SDA (Same Day ACH functionality included))
- Identify the Nacha Operating Rules to utilize when conducting an ACH Risk Assessment
- Developing an effective ACH Risk Management Program using information provided (during a fictitious hands-on activity)
- List the different types of ACH Risk and ways to help mitigate
- Define what’s needed for a successful ACH Risk Management Program
- Importance of monitoring the entire ACH program on a consistent basis
- Importance of Reporting details surrounding your ACH Program to the Board
- Determine the registration requirements for the ODFI with Nacha
- Direct Access Registration
- TPS (nested or not) Registration
- Contact Information for the ACH Contact Registry
- Summarize details of NEW Nacha Operating Rules amendment for ACH Risk Assessments and the TPS (including the “nested” TPS)
Who will Benefit:
Any payments professional working in the ACH Network will benefit from this course; these individuals could include operations, compliance, AR/AP, payroll, risk management, audit, legal counsel, management, risk officers, and AAP’s.
- 8:00 AM – Registration Begins
- 10:30 AM – 11:30 PM – LUNCH BREAK
- 11:30 PM – Seminar/Workshop Resumes
Overview on “How the ACH Network functions” and outline the Nacha Operating Rules on conducting an ACH Risk Assessment and developing an effective ACH Risk Management Program. Identifying the roles and responsibilities of the participants will help with identifying key pieces of the ACH risk assessment.
Define the different types of Risk and ways to mitigate. ACH Risk affects the ODFI and RDFI, Third-Party Service Providers and Third-Party Senders.
Overview on the recent Nacha Operating Rules amendment that addresses TPS and “nested” TPS (effective Sept 2022), identifying the existence and requiring an ACH Risk Assessment for ALL Third-Party Senders (nested or not). In addition, the Rules amendment includes the ODFI’s obligation regarding the TPS registration requirement to include the “nested” TPS. Included will be “defining” a TPS and “nested” TPS.
Begin the “hands-on” process of doing a Step-by-Step process of Assessing ACH Risk with Originating Companies and/or Third-Party Senders (TPS) using fictitious companies and one TPS (and “nested TPS), introducing the key components within such a program. Includes outlining details from guidance issued by FinCEN, FFIEC and the OCC and discussion on what’s needed for a successful ACH Risk Management Program, outlining guidance from FinCEN. Resources for workshop participants will be shared to aid in future ACH Risk Management programs.
- 8:00 AM – Workshop Resumes
- 10:30 AM – 11:30 PM – LUNCH BREAK
- 11:30 PM – Seminar/Workshop Resumes
Recap from previous day (outlining all discussions and progress during hands-on activity). Continuation with hands-on activity to include the development of an ACH Risk Management program for a “fictitious scenario” utilizing the companies/TPS from previous day for the ODFI program, (including the RDFI perspective when receiving and processing ACH transactions).
Discovering the NEW Rules amendment where Third-Party Senders (TPS) (and “nested” TPS) are also required to conduct an ACH Risk Assessment. Details are covered as we continue with a fictitious TPS and “nested” TPS while adhering to the requirements of the Nacha Operating Rules.
Outlining the requirements of the ODFI and registration of TPS and “nested” TPS and the elements of that information required on nacha.org. Discussion on other registration requirements for the ODFI.
To effectively complete an effective ACH Risk Management Program, discussion on checklists to ensure all key components are included. In addition, the importance of monitoring the entire ACH program on a consistent basis (an on-going effort), and reporting details surrounding the ACH Program to the Board will be discussed.
Donna K Olheiser
Owner, Dynamic Mastership, LLC
Donna founded Dynamic Mastership, LLC in December 2014 in an effort to utilize her 24+ years’ experience in the financial services industry, by sharing her passion for training financial institutions and organizations on the Rules and processes for electronic payments (with her specialty being ACH payments). She holds the Accredited ACH Professional (AAP) designation (achieved in 2004). Donna’s experience before founding Dynamic Mastership, includes 9 years' serving as the Education Service Director at a Regional Payments Association (RPA), where she managed and facilitated the entire Education program for nearly 800 financial institution members. Prior to that, Donna spent 14 years with the Federal Reserve Bank of Minneapolis in various departments, where she started her training career as the Training and Development Specialist in 2003.
Donna is a certified Master Trainer who continually uses her extensive knowledge, experience, enthusiasm and passion for transferring payment processing details, while using the adult learning theory is remarkable! Her training style has helped many payment professionals remain consistently informed of the NEW and ever-changing NACHA Operating Rules and explaining how the Rules apply when performing daily operational tasks including complex return and exception processing. She incorporates scenarios and examples in her detailed training, so the Rules are easy to comprehend and apply to real-life day-to-day ACH processing. Donna's ability to engage the learner through the entire training event helps the adult learner apply what they've learned during and after each training session.
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