Who Handles ACH Fraud Monitoring?

What changed, and when

Nacha's second fraud-monitoring phase covers remaining non-consumer originators, third-party service providers and third-party senders, with related credit-monitoring requirements for receiving institutions. The rule page lists June 19, 2026, and explains that June 22 is the practical effective date because of the holiday. It describes risk-based processes and at least annual review. This is an existing 2026 development, not a new October announcement.

Sources: Nacha: Risk Management Topics - Fraud Monitoring Phase 2

MerchantBridge analysis: clarify ownership before adding a payment method

A merchant considering ACH should know what its provider does and what remains with the business. That conversation is more useful when it follows the actual payment flow. Identify how a payment is authorized, how information reaches the provider and what happens when an exception is flagged.

For example, if one employee updates payout details and another handles customer support, make clear who reviews a suspicious change and whom they contact. Do not assume that purchasing a software feature assigns every responsibility to the vendor. The appropriate process depends on the role and arrangement; confirm it with the bank or provider.

• Ask which entity is the originator and which responsibilities apply to your role.
• Clarify who monitors activity and where exceptions are escalated.
• Ask how authorization, returns and customer questions are handled.
• Confirm who reviews the procedures and what evidence of that review is kept.

Put ACH requirements beside the business requirements

Describe why customers need ACH, which transactions you want to support and how settlement timing fits your operations. Keep that separate from the product-category review. A different payment method does not automatically make a restricted business eligible.

If you already use cards, do not assume the ACH arrangement has the same approval, reporting or support process. Ask about the proposed service explicitly and retain the provider's answers. For questions about the rules' application to your business, consult the provider and qualified advisers.

How MBA can support the processing conversation

MerchantBridge can review ACH/eCheck requirements alongside the wider merchant profile and explore whether potential payment relationships can evaluate them. We do not determine a merchant's legal obligations or certify compliance with Nacha rules.

The useful starting point is a factual description of your category, customers, proposed payment flow and operating needs. That lets the review distinguish a suitable payment-method discussion from an unsupported workaround.