New NACHA Rule for ODFI's with ACH Third-Party Senders and Registration, Plus the ODFI's BSA/AML Requirements

Duration: 60 Minutes
Effective September 2017, a NACHA Operating Rules amendment has been approved requiring Originating Depository Financial Institutions (ODFI's) to either register its Third-Party Sender customers' with NACHA, or provide a statement that it has no such Third-Party Sender relationship. This rule will impact all Originating Depository Financial Institutions (ODFI's) in the ACH Network.
NACHA Rule for ODFI’s BSA/AML Requirements
Instructor: Donna K Olheiser
Product ID: 505125
A Third Party Sender is defined as an intermediary between the ODFI and the originator that performs ACH origination services on behalf of an originator or another Third Party Sender.

Financial institutions that have this Third-Party Sender relationship should be aware of not only the new network Rule, but also the regulatory guidance and implications this type of relationship can have on the ODFIs BSA/AML program.

Objectives of the Presentation
  • Define a Third-Party Sender and the minimum information about them to register with NACHA
  • Illustrate how to identify a Third-Party Sender relationship and tips on how to keep up on this going forward
  • Outline maximum timeframe to complete the registration process to be in compliance with the NEW Rule
  • Identify how regulatory requirements with BSA/AML for the ODFI affects relationships with Third-Party Payment Processors (Third-Party Senders)
  • List best practices used in the industry when entering or continuing in a Third-Party Sender relationship
  • Describe the risk factors and risk mitigation with BSA/AML and Third-Party relationships and what that means
Why should you Attend
With the implementation of this new Third-Party Sender Rule, effective in September 2017; ODFI's need to be able to identify if they have a Third-Party Sender relationship and report accordingly (a. they do or (b. they don't with NACHA.

This session will outline how to identify a Third-Party relationship and what minimum information is required for the registration process, and outline the details of how to ensure you are continually in compliance with this new rule, not only in September but also into the future.

A Third-Party Sender is also a type of Third-Party Payment Processor and the FFIEC indicates that processors generally are not subject to BSA/AML regulatory requirements. As a result, some processors may be vulnerable to money laundering, identity theft, fraud schemes, or other illicit transactions, including those prohibited by OFAC.

The bank's BSA/AML risks when dealing with a processor account are similar to risks from other activities in which the bank's customer conducts transactions through the bank on behalf of the customer's clients. When the bank is unable to identify and understand the nature and source of the transactions processed through an account, the risks to the bank and the likelihood of suspicious activity can increase.

This session will help identify what the requirements are with BSA / AML in relation to this new Third-Party Sender Rule.

Areas Covered
  • Highlights of how to determine a Third-Party Sender relationship and methods used to help identifying
  • How regulatory requirements affect this type of relationship for the ODFI
  • ACH Network Rule on Third-Party Sender Registration that becomes effective September 2017
  • Tips on preparing for the TPS Rule based on your role at the ODFI (internal audit, compliance, risk management, cash management)
  • BSA/AML requirements of third party relationships and regulatory expectations based on industry threats
  • Preparing for regulators examining your BSA/AML processes to ensure you've included any third-party sender relationships
  • Best business practices for approving, onboarding and maintaining third-party sender relationships, and ensuring you are in compliance with the NEW Third-Party Sender Rule in September and in the future
Who will Benefit
  • ACH Operations Staff
  • Compliance Officers
  • ACH Auditors
  • ACH Managers
  • Electronic Payments Professionals
  • AAP's – keeping up with changes in ACH Rules and wanting to earn AAP Continuing Education Credits
  • Anyone who wishes to enhance their knowledge of the new NACHA Operating Rules
  • Audit Departments (within financial institutions) or external Audit Firms
  • Third-Party Payment Processors
  • Third-Party Senders
$300
Recorded Session for one participant
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Instructor Profile:
Donna K Olheiser, AAP, is the vice president of Education Services and founder of Dynamic Mastership, LLC. She is an enthusiastic and energetic Certified Master Trainer with over 14 years' training experience. She has designed and facilitated over 100 training sessions each year with her expertise being the rules for companies and financial institutions when processing electronic (specifically ACH) payments, then scheduling the events to facilitate and deliver the material through a variety of venues (webinars, teleseminars, in-person workshops, including regional and national conferences).

Her extensive knowledge, enthusiasm and passion for transferring payment processing knowledge using the adult learning theory is remarkable and has helped many payment professionals perform daily operational tasks including exception processing while remaining compliant with the NACHA Operating Rules. She uses scenarios and examples to bring the learning home, easy to comprehend and apply to real-life day-to-day ACH processing. Ms. Olheiser's ability to engage the learner through the entire training event helps the adult learner apply what they've learned during and after each training session.

She has over 24 years of experience in the financial services industry which includes 9 years' experience as the education service director at a Regional Payments Association (RPA), where she managed and facilitated the entire education program for nearly 800 financial institution members. Prior to that, Ms. Olheiser spent 14 years in various departments with the Federal Reserve Bank of Minneapolis and also holds the Accredited ACH Professional (AAP) designation (achieved in 2004).
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