Two NACHA Rules Now Effective

NACHA rule, Limitation on Warranty Claims effective June 30, 2021, limits the length of time in which a Receiving Depositary Financial Institution (RDFI) is permitted to make a claim against the Originating Depositary Financial Institution’s (ODFI’s) authorization warranty.

• One year from settlement date for entry to non-consumer account.
• For consumer accounts: first 95 calendar days from the settlement date of the first unauthorized entry will always be covered. If outside the first 95 days, then 2 years from the settlement date of the entry.
  

In the NACHA rule, Reversals and Enforcement, the Reversals rule became effective June 30, 2021, and the Enforcement rule became effective Jan. 1, 2021.

This NACHA rule addresses the improper use of reversals. It expands permissible reasons for a reversal to include a “wrong date” error:

• The reversal of a debit entry that was for a date earlier than intended by the originator; or
• A credit entry that was for a date later than intended by the originator.