NEW Nacha Rule - Third-Party Sender (TPS) Roles and Responsibilities

Recent updates to the Nacha Operating Rules are further clarifying the Roles and Responsibilities of Third-Party Senders (TPSs) who use the ACH network.  The purpose of the update is to explicitly identify the use of not just TPSs but also “nested” TPS.
The update is also addressing the requirement that a TPS conduct a Risk Assessment.
Both Rules become effective Sept 30, 2022, with a 6-month grace period for certain aspects of each Rule.

Key points surrounding TPS Roles and Responsibilities and what they mean to the participants in the ACH Network will be detailed. In this session, the trainer will:

• Define a Third-Party Sender (TPS)
• Define a “nested” Third-Party Sender (TPS)
• List details of agreement requirements between which parties and why this is necessary for compliance
• Explain current TPS agreements in place and whether is re-papering required, guidance for moving forward
• Identify an ACH Risk Assessment and its purpose
• Outline who needs to do the ACH Risk Assessment based on this NEW Rule
• Detail certain aspects of the Rule that have a 6-month grace period

This session will help the attendee to identify a Third-Party Sender (TPS) and a “nested” TPS.  In addition, we will cover the details needed in the agreements between all parties and what parties are based on their role.  Discussion on the registration requirement for both the TPS and the nested TPS and what that means to the ODFI.

Details on what individual aspects of the Rules have a 6-month grace period and how this affects compliance with these two NEW Rule amendments.

• Bank operations staff
• New employees in the payments industry
• Bank managers and payment professionals
• CEOs and CFOs
• Risk, Compliance, and Audit personnel
• Aspiring AAPs and current AAPs for AAP CE Credits
• Financial Institutions
• Banking Professionals
• Audit Persons
• ACH operations staff
• ACH Audit personnel

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).