Nacha Rules state that ODFIs take on all the warranties and responsibilities for their Originator’s compliance with the Nacha Rules. But what about the Originator? What are their roles, responsibilities, and obligations?
Electing to originate TEL and debit WEB entries can expose ODFIs to additional risk. How is that liability shared between the Originator and the ODFI and what controls can be implemented to mitigate risk from originating debit WEB and TEL entries?