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Payments Pulse

Payments Pulse
The Clearing House
Payments Pulse

Industry News & Resources

Risk Management Practices for Overdraft Protection Programs

This OCC bulletin is for national banks and other OCC regulated depository institutions. It discusses how certain overdraft practices may present heightened risks of violating prohibition against unfair or deceptive acts or practices.

Source: OCC Bulletin

Nacha Request For Comment - 9 Proposals

Nacha is issuing for comment a set of proposals to amend the Nacha Rules related to ACH Risk Management. This set of proposals includes seven proposals related to ACH credit risk management and two proposals related to ACH debit risk management. Comments are due by June 16, 2023.

Source: Nacha

Nacha Request for Information

Nacha is looking for feedback from industry stakeholders on four risk management topics. Responses should be provided by Friday, June 30, 2023. To learn more about these Request for Information.

Source: Nacha

Take the Nacha Rules Products Satisfaction Survey and Win!

Nacha is reaching out to businesses and organizations who originate payments to gather feedback about the user experiences with the Nacha Operating Rules & Guidelines product formats. Nacha will use this feedback to make informed decisions for improving products and services for your needs.

Please take this five-minute survey and be entered to win a $250 gift card. Please also pass along this important survey to your business originators Get started.

Payments Education

Congratulations to our TPI Scholarship Winner!

We want to send out a special congratulations for our 2023 TPI Scholarship winner Lora H., M&T Bank. Enjoy what TPI On Campus has to offer this year, with both intermediate and advanced-level curriculum for payment professionals. Share what you learn with your teams and we look forward to announcing our next winner in 2024!

New Series: Ask an Auditor "Ed Talks"

Want to get in a room with an auditor? Do you want to dig deeper into ACH compliance? TCHPA has a new short, 5-part mini-series, where one of our educators talks to one of our TCHPA auditors on your behalf. Topics are going to range from general ACH Rules requirements for RDFIs and ODFIs, Considerations for Third-Party Senders, and ACH Risk Assessments. Keep your eye on the TCHPA Education Calendar because this series will be available soon.

TCHPA Education for June:

In-Person Events:

Virtual Events:

TCHPA Resources:

Reg E All-in-One Resource

Regulation E procedures can sometimes feel tricky. Our Regulation E Resource provides essential sample documents that you need to establish or enhance your Regulation E error resolution processes and maintain compliance! Check out what's included in this resource here.

ACH Check Conversion Resource

Do you have a hard time understanding the difference between ARC, BOC, and POP? Check out our ACH Check Conversion resource guide to help you to understand the differences between these three SEC Codes, giving you an upper hand in understanding check conversions!

The following is provided for informational purposes only and doesn't constitute legal advice.

We Get Questions...


Q and A
Q.)  What's the difference between a Third-Party Service Provider (TPSP) and a Third-Party Sender (TPS)?
A.)  According to Article Eight of the 2023 ACH Rules and Operating Guidelines, a Third-Party Service Provider is " an Organization that performs any functions on behalf of the Originator, the Third-Party Sender, the ODFI, or the RDFI (not including the Originator, ODFI, or RDFI acting in such capacity for such Entries) as related to the processing of ACH Entries, including:
  • The creation of the Files, or
  • Acting as a Sending Point on behalf of the Participating DFI, or
  • Acting as a Receiving Point on behalf of the Participating DFI.
  • An Organization acting as a Third-Party Sender also is a Third-Party Service Provider.
Common examples you'll find in the banking industry of TPSP would be your core processor, who would send ACH Entries to the Operator on your behalf, or accept them from the Operator on your behalf. This could also be a firm that helps an Originator create an ACH File, helping them stay compliant for those who don't have the bandwidth to create their own ACH files.

What about a Third-Party Sender? A TPS is a subset of a TPSP. Which means, that a Third-Party Sender is also always a Third-Party Service Provider. Article Eight of the 2023 ACH Rules and Operating Guidelines defines a Third-Party Sender as" a type of Third-Party Service Provider that acts as an intermediary on behalf of an Originator or another Third-Party Sender in Transmitting Entries between the Originator and the ODFI (of the ACH Operator on behalf of the ODFI via Direct Access), where there is not an Origination Agreement directly between the Originator and the ODFI.

A Third-Party Sender is never the Originator for Entries it Transmits on behalf of another Organization; however, a Third-Party Sender of Entries may also be an Originator of other Entries in its own right."

A simple way of breaking this down could be that a TPS is an organization that transmit ACH Entries into the ACH Network on behalf of another organization, the Originator. And that Originator has an ACH Agreement with the TPS, not the ODFI. Common examples of TPSs include property management companies, payroll companies, and organizations that transmit ACH entries to fund accounts, where such companies/organizations do not have an agreement with the ODFI.

Are you still not sure if an organization qualifies as a Third-Party Sender? Check out Nacha's Third-Party Sender Identification Tool, which walks you through a series of questions in a workflow-type process to help you better understand your status.

Instant Payments

Q.)  Are FedNow or RTP considered digital currencies?
A.)  The straight-forward answer to that is no. RTP and FedNow are both considered payment rails for the instant payments industry. RTP Is available now, and FedNow is expected to launch mid-July. Both rails will be available for processing 24 hours a day, 7 days a week, 365 days a year. These rails are credit push rails only, where the sender will be sending funds to the receiver. The funds received are available in the receiver's account at their financial institution.
So what is digital currency? According to Forbes Advisor, "Digital currency is any currency that's available exclusively in electronic format. [...] What differentiates digital currency from the electronic currency that's already in Americans' bank accounts is that digital currency never takes physical forms." Examples of digital currency are cryptocurrencies, stablecoins, and central bank digital currency (CBDC).

Member Support

TCHPA Fact Sheet

Remember, when you need support from The Clearing House Payments Authority (TCHPA), you can reach our Member Services staff directly by calling 800-875-2242 and choosing option 3, or by emailing

Professionals in every trade have an association they rely on for industry expertise, support and resources. We're the Association for Payments People.

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Winston-Salem, NC 27107
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