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This session will cover “step-by-step” the audit process and requirements for each participant conducting an annual ACH audit, to help ensure their compliance with the Nacha Operating Rules.


  • Identify the participants in the ACH network required to conduct an annual ACH Rules Compliance Audit
  • Define what the General Audit Requirements are (now in Article 1)
  • Discussion on tools available in the Nacha Operating Guidelines for guidance when conducting the annual ACH Rules Compliance Audit.
  • Review the flexibility of each participant when following the Guidelines, which include the ODFI, RDFI, TPSP, and TPS within the Rules Book
  • Describe “how-to” to ensure Rules Compliance after determination of what ACH activities are being audited
  • Recommended areas to check (audit) in addition during the ACH Audit

The Nacha Operating Rules and Guidelines require that all participating depository financial institutions, third-party senders, and third-party service providers that provide ACH services to the RDFI or ODFI, conduct an annual ACH audit by December 31 of each year (ACH Rules, Article 1). There have been many Rules changes since 2019 that affect your annual ACH Rules Compliance Audit in 2022, including the verification of registration and accuracy of the info in the ACH Contact Registry (new in 2020!).

The annual ACH Rules Compliance Audit requires a precise examination of all ACH processes that a participant is involved in, then completing the “compliance test” of those processes to ensure compliance with the Nacha Operating Rules.
There are NEW Unauthorized Returns processes (with an additional ODFI monitoring requirement), PLUS a NEW ACH Contact Registry verification requirement added to the annual ACH Rules Compliance Audit!

This session will identify who needs to conduct an annual ACH Audit. In addition, outline the process for each participant that is required to conduct the annual Rules compliance Audit, plus offer tips and guidance for creating your own personalized ACH Audit (based on the ACH activities you utilize).


  • ACH Operations staff
  • Compliance Officers
  • Treasury professionals
  • Third-Party Payment Processors
  • Third-Party Senders
  • ACH Managers
  • Electronic Payments Professionals
  • ACH auditors (internal and external)

Donna K Olheiser, AAP, is the vice president of Education Services and founder of Dynamic Mastership, LLC. Donna is an enthusiastic and energetic Certified Master Trainer with over 14 years’ training experience. She has designed and facilitated over 100 training sessions each year with her expertise being the rules for companies and financial institutions when processing specifically ACH electronic payments, then scheduling the training events to facilitate/deliver the material through a variety of venues (webinars, teleseminars, in-person workshops, including regional and national conferences). Donna has over 24 years of experience in the financial services industry which includes 9 years’ experience 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, Ms. Olheiser spent 14 years in various departments with the Federal Reserve Bank of Minneapolis and also holds the Accredited ACH Professional (AAP) designation (achieved in 2004).

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