Key Takeaways: Nacha's Upcoming Rule Change- PaymentWorks

by Ashley Poynter

Content Manager

Key Takeaways From Our Webinar on Nacha’s Upcoming Rule Change

Last week’s virtual event brought together industry experts from PaymentWorks (me!) and Nacha Consulting (Mark Dixon) to unpack the implications of Nacha’s sweeping new ACH Operating Rules, which will come into effect in 2025 and 2026. If you missed it, here are the top insights your vendor management, finance, and compliance teams need to act on now.

1. RDFIs Must Respond Faster—Starting April 2025

2. Risk-Based Fraud Monitoring Is Now Mandatory

3. The Vendor Master File Is Your Fraud Surface

4. False Pretenses: The New Definition Driving Rule Design

5. Manual Phone Calls Aren’t Enough And Can Be Risky

6. What Compliance Looks Like in Practice

7. Automation Isn’t Just Helpful, It May Be Necessary

8. Chubb Now Recommends and Extends Coverage for Automated Systems

Why Nacha’s Upcoming Rule Change Matters & What You Should Do

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1. RDFIs Must Respond Faster—Starting April 2025

One of the most immediate changes hits Receiving Depository Financial Institutions (RDFIs): starting April 1, 2025, RDFIs must respond to “Request for Return” messages from ODFIs within 10 banking days.

This tighter window will require more coordination between banking partners and internal teams handling vendor onboarding, payment support, and treasury operations.

📌 Takeaway: If you’re relying on manual follow-ups, you risk missing return windows. Automated workflows and audit trails that flag returnable payments and route tasks accordingly will be critical.

2. Risk-Based Fraud Monitoring Is Now Mandatory

The biggest headline: Every ACH originator must implement a risk-based fraud monitoring process.

⏱ Effective Dates:

March 20, 2026, for originators with >6M payments sent or >10M received in 2023
June 22, 202,6, for everyone else

This shift stems from the rise of credit push fraud, including vendor impersonation, business email compromise, and misdirected payments triggered by fraudulent instructions.

Nacha now requires organizations to:

Establish internal risk assessments
Define low- vs. high-risk transactions
Tailor monitoring practices accordingly
Use validated data sources for bank account verification
Review and update the process annually

📌 Takeaway: Fraudsters are targeting your “exceptions”, like last-minute payment requests and vendor updates before fiscal year-end. A static policy isn’t enough; risk-based monitoring must evolve with threats.

3. The Vendor Master File Is Your Fraud Surface

I’m officially coining the term “vendor events”: any change or new entry in your vendor master file that introduces risk. Based on real PaymentWorks data:

More than 50% of vendor records will trigger changes or new entries in a given year
These include name changes, new tax IDs, remittance updates, and banking changes
Each of those is a fraud opportunity—particularly when handled manually or over email

📌 Takeaway: Even a 10,000-vendor file could result in 2,500+ phone calls a year just to verify account data. Unless automated, this process is hard to scale and easy to exploit.

4. False Pretenses: The New Definition Driving Rule Design

Nacha has formalized the concept of “false pretenses”—fraud triggered by a party misrepresenting their authority or identity to induce payment.

This includes:

Vendor impersonation
Fake bank change requests
Fraudulent email instructions
CEO/CFO impersonation (BEC-style attacks)

📌 Takeaway: If a payment is sent to a fraudster due to a false pretense, and you didn’t have a defensible, risk-based validation process in place, you could be considered negligent, not unlucky.

5. Manual Phone Calls Aren’t Enough And Can Be Risky

Yes, phone calls are still part of the fallback strategy when data validation fails. But they must be:

Auditable
Conducted using trusted, pre-verified contact numbers
Recorded when possible
Managed outside of high-risk times (e.g., quarter-ends, holidays)

But even with best practices, you still might be talking to a fraudster.

📌 Takeaway: Phone-based verification has limits and is labor-intensive. High-risk or high-volume teams should seriously consider automation.

6. What Compliance Looks Like in Practice

Having a “policy” isn’t enough. Nacha expects:

Written procedures
Documented reviews
Testing and audits
Evidence of a real-world, risk-informed process

In fact, just 15% of organizations today have a fully documented and tested verification process, according to AFP survey data shared in the session.

📌 Takeaway: If your current process can’t withstand a secret shopper or an audit request, it’s time to update it—especially with the upcoming enforcement lens.

7. Automation Isn’t Just Helpful, It May Be Necessary

The PaymentWorks team emphasized four pillars of a modern, automated vendor risk process:

Identity Verification—Validate TINs, legal names, and DBAs before you even begin bank verification.
Behavioral Screening & Predictive Signals—Spot anomalies (e.g., login from new geolocation or browser, activity spikes before large payments).
Bank Account Validation—Use third-party data sources and establish fallback phone verification when needed.
Payment Monitoring at Time of Disbursement—Ensure that, at the moment of payment, the vendor was verified and the process logged.

📌 Takeaway: Whether you build your own system or use a turnkey platform, automation is how most organizations will meet—and maintain—compliance at scale.

8. Chubb Now Recommends and Extends Coverage for Automated Systems

In a standout moment, Taylor shared that Chubb, one of the largest crime insurers globally, now:

Recognizes PaymentWorks as a preferred loss prevention provider
Extends supplementary insurance coverage when their systems are used
Focuses on “insurable onboarding” aligned with Nacha’s expectations

📌 Takeaway: Insurers see the reality of this risk, and they’re rewarding organizations that take proactive, automated steps to mitigate fraud.

Why Nacha’s Upcoming Rule Change Matters & What You Should Do

These rule changes mark the most comprehensive update to Nacha’s ACH Operating Rules in two decades. But they’re more than just policy; they’re a response to the reality of rising fraud risk.

If your current process involves email threads, spreadsheets, or manual bank checks without centralized oversight or auditing, you are not ready.

But you can be with the right platform.

At PaymentWorks, our vendor onboarding and verification platform is purpose-built for this moment:

Automated, risk-based validation
Full audit trails
Real-time fraud detection
$2M indemnification protection
Trusted by Chubb, recommended by Nacha Consulting

Start preparing today. Compliance deadlines may feel far off, but building, testing, and documenting your risk-based process takes time.

Want to see how it works? Talk to our team about Nacha-compliant vendor onboarding.

Get Ready For Vendor Management Appreciation 2025

The Vendor Management Appreciation Day (#VMAD) celebration continues in 2025! And you should join us.

Why? Because there’s no expiration date on honoring one of the most important, under-recognized roles across industries: vendor management.

Join us in observing Vendor Management Appreciation Day (VMAD)! We’re gearing up for the 2025 celebration, and we want you to be a part of it!

VMAD is a new holiday geared toward unifying vendor management professionals and celebrating innovation in the field.

Moreover, we’ve released gifts each month to help you supercharge your vendor management efforts. Additionally, we’re planning some awesome events so everyone can connect and celebrate the important, strategic role of vendor management.

In the meantime, learn more here, and grab some free vendor management goodies.