Q.) It's no secret that when processing debits in the ACH Network the Originator is required to FIRST obtain authorization from the Receiver. Per Nacha Rules (Nacha Operating Rules, Article II, Subsection 184.108.40.206) , the Originator is required to be able to reproduce the authorization for two years from the settlement date or from the revocation of the authorization. What happens though, if the ODFI receives a request for an Originator that is no longer with them and it's within the two year time period?
A.) The ODFI is still responsible for providing that proof of authorization to the RDFI. Nowhere in the Nacha Operating Rules, is there a caveat that the ODFI is relieved of this obligation because the relationship changed. Instead, the Rules do specify what are the warranties that are put into effect for each entry transmitted into the ACH Network by the ODFI, including and not limited to the entry being authorized by the Receiver (Nacha Rules, Article II, Subsection 220.127.116.11). Ideally you will have a process implemented on how to obtain proof of authorization from a previous Originator before ever being asked for one.