on unauthorized return rates.  The effective date of these rules is March 21, 2008.  If NACHA suspects an ACH Originator or Third-Party Sender of having an unauthorized return rate exceeding 1%, the ODFI will be required to provide NACHA with requested supporting information and may face penalties.

 

Every RDFI and ODFI will face new regulatory requierments in less than 12 months as the IAT amendments to the NACHA rules will require every ACH payment entering or exiting the United States to be identified and formated as an International ACH Transaction (IAT) and EACH transaction must be reviewed for OFAC compliance.