Third-Party Sender Registration
Request for Comment - ACH Participant Survey
August 17, 2015
COMMENTS DUE BY FRIDAY, OCTOBER 9, 2015.
NACHA requests comments on proposed changes to the NACHA Operating Rules that would require
Originating Depository Financial Institutions (ODFIs) to identify their Third-Party Senders to NACHA
through a centralized registry. The proposed amendments would enumerate data elements that ODFIs
with Third-Party Sender customers would be required to provide about themselves and their Third-Party
Senders.
The survey should be completed online at https://www.nacha.org/rules/proposed by Friday, October 9,
2015. For convenience, the survey questions are also provided within this document to assist
respondents in gathering information from within their organizations.
NACHA STAFF CONTACTS
Administrative questions:
Questions:
Maribel Bondoc, Manager, Network Rules
Fax (703) 787-0996
E-mail: mbondoc@nacha.org
Peter Hohenstein, AAP, Senior Director, Network Rules
E-mail: phohenstein@nacha.org
Danita Tyrrell, AAP, Director, Network Rules
E-mail: dtyrrell@nacha.org
SECTION I - RESPONDENT INFORMATION
All Respondents
Name
Title
Organization
City, State
Phone
Email
Request For Comment – Third-Party Sender Registration
ACH Participant Survey, 8/17/15; Page 2
Please indicate your organization’s role(s) in the ACH Network:
ODFI
Regional Payments Association
RDFI
Direct FI Member
ACH Operator
Government
Originator
Third Party Service Provider
Receiver
Software Vendor
Other:
What areas of your organization provided input for the responses to this survey?
Operations
Wholesale/corporate banking/treasury mgt
Product managers
Customer service
Legal
Compliance
Information
Retail/online banking
Technology/software
Other:
Financial Institution Respondents
Asset Size
less than $250 million
$250 million - $999 million
$1 billion - $100 billion
Greater than $100 billion
SECTION II: REQUEST FOR COMMENT
1. Does your organization support the proposal that ODFIs
would be required to register their Third-Party Senders with
NACHA?
Please explain why or why not:
Yes
No
Don’t know
No opinion
Request For Comment – Third-Party Sender Registration
ACH Participant Survey, 8/17/15; Page 3
2. Please indicate if you agree whether the following should comprise the initial registration
information:
Yes,
Yes, but
No
Don’t
No
required
optional
know
opinion
field
field
ODFI Information
ODFI name
ODFI contact name and title
ODFI contact telephone number
ODFI contact street address
ODFI contact email
Is there other ODFI information that should be part of the initial registration?
Third-Party Sender Information
RTN used by Third-Party Sender
Name of organization
Company Identification used in ACH
Principal city and state location
Is there other Third-Party Sender information that should be part of the initial registration?
3. Please indicate if you agree whether the following should comprise the supplemental
registration information, upon request from NACHA:
Yes,
Yes, but
No
Don’t
No
required
optional
know
opinion
field
field
Third-Party Sender Additional Information
DBA names (if any)
Tax Identification Number
Website address
Primary contact name and title
Primary contact telephone number
Primary contact email address
List of principals, including title
Approximate number of Originators
A statement regarding whether the TPS
transmits credit entries, debit entries, or
both
Request For Comment – Third-Party Sender Registration
ACH Participant Survey, 8/17/15; Page 4
4. Does your organization agree that an ODFI should register a
Third-Party Sender within 30 days from the date it starts
originating entries?
If no, what should the period be? If other, please specify:
Yes
No
Don’t know
No opinion
Prior to
origination
Less than 30
days
60 days
90 days
Other
5. Does your organization agree that an ODFI should update
the registration after any change to the required information
previously provided?
Yes
No
Don’t know
No opinion
6. Does your organization agree that an ODFI should update
the registration after the termination of an origination
relationship with a Third-Party Sender?
Yes
No
Don’t know
No opinion
7. Does your organization agree that, when requested, an ODFI
should provide supplemental registration to NACHA within
10 Banking Days?
Yes
No
Don’t know
No opinion
Less than 10
Banking Days
Within 30 days
Other
If no, what should the period be? If other, please specify.
8. Does your organization agree that ODFIs should pay a
registration charge for each Third-Party Sender that it
registers?
Yes
No
Don’t know
No opinion
Request For Comment – Third-Party Sender Registration
ACH Participant Survey, 8/17/15; Page 5
If yes, what do you think is a reasonable registration charge per
Third-Party Sender?
$100
$250
$500
$1,000
Other
9. Do you have any other comments or suggestions on this proposal not already covered?
For ODFIs Only
10. As an ODFI, do you originate for Third-Party Senders?
If yes, for how many Third-Party Senders?
(Note: This information is being requested to help estimate
the scope of the registry.)
Yes
No
1-10
11-50
51-100
More than 100
If you have more than 100 Third-Party Senders, please
provide an estimated number:
11. If you answered “yes” to Question 10, do you currently
maintain registration-type information for each Third-Party
Sender?
Yes
No
Don’t know
SECTION III – IMPACT AND PROPOSED EFFECTIVE DATE
Impacts
12. On a scale of 1-5 (with “1” representing no systems/software impact, and “5” indicating extensive
systems/software impact), please estimate the impact to your organization related to the following
proposal:
1=
2=
3=
4=
5=
No
Minimal Moderate Large Extensive Don’t
No
impact
impact
impact
impact
impact
know opinion
Third-Party Sender
initial registration
Response to request
for supplemental
registration
information
Request For Comment – Third-Party Sender Registration
ACH Participant Survey, 8/17/15; Page 6
13. Please identify which of your systems would be impacted (check all that apply).
Core/
DDA
&
TDA
ACH
Exceptions
/returns
Procedures
/staff
training
Database/
tables
Other
systems
Don’t
know
Third-Party
Sender initial
registration
Response to
request for
supplemental
registration
information
14. Please estimate the anticipated cost of the impact of the proposal.
Less than
$10,000
$10,000 $49,999
$50,000 $99,999
Greater
than
$100,000
Don’t
know
Third-Party Sender initial
registration
Response to request for
supplemental registration
information
Proposed Effective Date
15. Does your organization support an effective date of June
16, 2017? This would be the date by which ODFIs must
register existing Third-Party Senders.
If “no,” what effective date would you support?
Yes
No
Don’t know
No opinion
March, 2017
September, 2017
January 1, 2018
Other
If other, please specify: