Rules Enforcement

Question 1

What is the purpose of the ACH Fines and Enforcement?

Answer 1

The purpose of these enforcement mechanisms is to maintain the quality of ACH services and the satisfaction of Participating DFIs and their customers by promoting compliance with these rules and reducing the risks to Participating DFIs and their customers by limiting the number of unauthorized Entries.

Question 2

The Rules Enforcement panel may direct an ODFI to suspend the Originator or Third-Party Sender from originating if it has determined that there is a __?__ Rules Violation.

Answer 2

Class 3

Question 3

An ODFI that is unable to provide NACHA with a copy of a requested ACH Audit report will be considered a __?__ Rules Violation.

Answer 3

Class 2

Question 4

After the fourth Rules Violation of failure to comply with an NOC, an ODFI is assessed a $100,000 fine by NACHA for a Class 2 Rules Violation. The ODFI made every attempt to let its Originator know it was the Originator’s obligation to correct the payment information; however, the Originator continued to send the entry incorrectly. The ODFI is pursuing legal action toward the Originator to recoup the $100,000 fine. The dispute is interpreted according to the provisions of:

Answer 4

State Contract Law
Note: The answer is State contract law because the NACHA Rules fine the ODFI for the Rules Violation and the ODFI can only recover the fine based on the terms within its ACH Origination Agreement with its Originator.

Question 5

What is the maximum fine for a 3rd recurrence of a Class 1 Rules Violation?

Answer 5

$5,000.00

Question 6

The maximum fine for a Class 3 Rules Violation is __?__.

Answer 6

$500,000 per month until resolved

Question 7

A fourth recurrence of a Rules Violation is what violation class?

Answer 7

Class 2

Question 8

Who is responsible for suspending an Originator if there is a Class 3 violation?

Answer 8

The Rules Enforcement Panel