ACH Third-Party Sender Compliance Checklist

This document is a checklist for ACH Third-Party Senders outlining their compliance responsibilities with the Nacha Rules. It specifies the requirement for an annual audit of compliance, which must be completed by December 31. The checklist includes the necessity to provide U.S. Bank with audit results and detailed information about underlying customers for whom ACH transactions are originated. This includes customer identification details, transaction history, and authorization procedures. The document also emphasizes the importance of maintaining clear and understandable authorization records and includes guidelines for a sample ACH services agreement that meets Nacha requirements. This agreement must outline the customer's obligations under the Nacha Rules, including adherence to U.S. laws and the conditions under which the agreement can be terminated. Additionally, it highlights the need for thorough due diligence on customers during onboarding, including monitoring and reporting programs and employee training.