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Q.) Must we provide
our ACH Origination customer with the ACH Rules at account set up?
A.) The ACH
Rules call for the Originator to agree to be bound by the Rules in your ODFI/Originator
agreement; however, the Rules are silent on how the ODFI ensures that the Originator is aware
of, and operating in compliance with, the Rules. As the ODFI, it is your responsibility to
make sure the Originator has the capacity to follow the Rules. Providing your Originators with
access to the Rules at set-up, and again at the beginning of each year thereafter, is a best
practice for both compliance and risk management.
If your Origination agreement includes more specific language about access to the Rules,
you’ll want to take that into consideration as well. For additional information, see the 2020
ACH Rule Book, Rights and Responsibilities of ODFIs, their Originators and Third-Party
Senders, Subsection 2.2.2 (page OR5-6).
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