Third-Party Sender & Service Provider ACH Compliance Audit


The NACHA Operating Rules require that all Third-Party Service Providers and Third-Party Senders conduct an audit of compliance with the Rules annually by December 31st.

The Rules further state, “Each Participating DFI, Third-Party Service Provider, and Third-Party Sender must, in accordance with standard auditing procedures, conduct an internal or external audit of compliance with provisions of the ACH Rules…”. The effectiveness of the internal /self-audit or external audit is greatly reduced if it is not performed by knowledgeable individuals, independent and objective of the ACH environment.

Third-Parties play a valuable role in the ACH Network and are reliant on partnership with the Originating Depository Financial Institution (ODFI). ACH Rules compliance plays a critical component in maintaining this partnership.

At ePayAdvisors, we understand that no two Third-Parties are the same. Each Third-Party is structured differently, has unique business strategies, processes, and services, so why limit the audit to Appendix Eight when your risk doesn’t stop there. Our team of Accredited ACH Professionals (AAP) have performed hundreds of ACH Audits. Our audit scope goes beyond Appendix Eight, and includes:

  • All of the legal framework outlined in the NACHA Operating Rules
  • The NACHA Operating Guidelines which provides guidance on how to comply with the Rules
  • Sound Business Practices


We provide an actionable audit report and certification letter that can be provided to your ODFI(s) or critical partners. As strategic partners, your exit meeting will include a review of upcoming ACH Rule changes that may impact your ACH operating environment.

Give your ODFI confidence in the quality of the ACH Audit; experience the ePayAdvisors’ difference and contact us today!



Article 8 of the NACHA Operating Rules Defines the Definitions and Terms used in the Rules

SECTION 8.106 “Third-Party Sender”

a type of Third-Party Service Provider that acts as an intermediary in Transmitting Entries between an Originator and an ODFI, including through Direct Access, and acts on behalf of an Originator or another Third-Party Sender. A Third-Party Sender must have an Origination Agreement with the ODFI of the Entry. A Third-Party Sender is never the Originator for Entries it Transmits on behalf of another Organization. However, a Third- Party Sender of Entries may also be an Originator of other Entries in its own right.

SECTION 8.107 “Third-Party Service Provider”
an Organization that performs any functions on behalf of the Originator, the Third-Party Sender, the ODFI, or the RDFI (not including the Originator, ODFI, or RDFI acting in such capacity for such Entries) related to the processing of Entries, including the creation of the Files or acting as a Sending Point or Receiving Point on behalf of a Participating DFI. An Organization acting as Third- Party Sender also is a Third-Party Service Provider.


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Pam Rodriguez, AAP, CIA, CISA
President & CEO  
prodriguez@epayadvisors.com
800-475-0585 ext. 1603