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NACHA Rule Change
September 2014: Prenote Waiting Period Change and B2B Authorization Records
ACH Rules Updates - Effective September 19, 2014
Prenote Waiting Period Changed from 6 to 3 Banking Days
There are two upcoming ACH Rule changes pertaining to ACH origination processing. First, if you are accustomed to using prenotes to validate the receiver's bank routing and account information and waiting six banking days before initiating 'live' entries, that time period has been reduced from six to three banking days. Keep in mind that prenotes continue to be optional and they validate the bank routing and account information but not that the receiver's name on the prenote is connected to or associated with the account. This new rule is located in the NACHA Rules at Article 2, Subsection 2.6.3. Following is a copy of this rule for your convenience:
An Originator that has originated a Prenotification Entry to a Receiver's account may initiate subsequent Entries to the Receiver's account as soon as the third Banking Day following the Settlement Date of the Prenotification Entry, provided the ODFI has not received a Return or a Notification of Change related to the Prenotification. If the ODFI receives a Return Entry or a Notification of Change in response to the Prenotification by the opening of business on the second Banking Day following the Settlement Date of the Prenotification, the Originator must not transmit subsequent Entries to the Receiver's account until it has remedied the reason for the Return Entry and made the correction requested by the Notification of Change.
Providing Record of B2B Authorizations within 10 Banking Days
The second rule pertains to you if you are originating ACH entries to non-consumer accounts which you might classify as vendors, trading partners, or business customers. Currently, the ACH Rules state (Article 2, Subsection 2.3.1) that the Originator must obtain authorization from the Receiver and that the Originator must obtain the Receiver's agreement to be bound by the ACH Rules (Article 2, Subsection 220.127.116.11. The ACH Rules are not specific regarding how the agreement is to be obtained or in what form. However, the approved Rule change will obligate ACH originators that are sending ACH entries to other companies to supply evidence of authorization or supply contact information as requested by the receiving company. Originators must provide this information within 10 banking days of a written request from the receiving financial institution. You are encouraged to review your policies and procedures with regards to obtaining and retaining agreements and authorizations so that documentation can be quickly located in the event that PNC or your company is asked to provide this information. Furthermore, this new rule is located in the NACHA Rules at Article 2, Subsection 18.104.22.168 Following is a copy of this rule for your convenience:
Provision of the Record of Authorization (New Subsection) For a CCD, CTX, or Inbound IAT Entry to a Non-Consumer Account:
(a) Upon receipt of an RDFI's written request for evidence of authorization of the Entry, the ODFI must provide either (1) an accurate record evidencing the Receiver's authorization, or (2) the contact information for the Originator that, at a minimum, includes (i) the Originator's name, and (ii) the Originator's phone number or email address for inquiries regarding authorization of Entries. This record of authorization or contact information must be provided to the RDFI within ten Banking Days of receipt of the request without charge.
(b) At the request of its ODFI, the Originator must provide either (1) an accurate record evidencing the Receiver's authorization or (2) contact information for the Originator that, at a minimum, includes (i) the Originator's name, and (ii) the Originator's phone number or email address for inquiries regarding authorization of Entries. The Originator must provide the record or information to the ODFI for its use or for the use of an RDFI requesting the information in such time and manner as to enable the ODFI to deliver the information to the requesting RDFI within ten Banking Days of the RDFI's request.
Important Legal Disclosures and Information
Bank deposit, treasury management and lending products and services, and investment and wealth management, and fiduciary services are provided by PNC Bank, National Association, a wholly-owned subsidiary of PNC and Member FDIC. Lending and leasing products and services, including card services and merchant services, as well as certain other banking products and services, may require credit approval.
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