Effective September 30, 2022, Nacha will add two rules clearly defining roles and responsibilities for Nested Third-Party Senders and the Third-Party Senders Risk Assessment. Both rules allow for a six-month grace period. Specifics are detailed in Nacha’s Third-Party Sender Roles and Responsibilities (Off-site) ruling.
The first rule will include:
- Definition of a Nested Third-Party Sender (TPS)
- Origination Agreement update requirements for a Nested TPS relationship
- How to establish the chain of agreements and responsibilities within a Nested TPS relationship
- Update TPS registration to determine existence of a Nested TPS relationship
The second rule requires TPSs to complete and conduct their own ACH activity Risk Assessments.
For additional information on either rule, please visit Third-Party Sender Roles and Responsibilities (Off-site).
