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#654631 - 12/20/06 02:20 PM NACHA Requirement- agreements
comply123 Offline
Member
Joined: Dec 2005
Posts: 76
Does the Bank have to have an agreement in place with the third-party service senders used by the Originators?? For example, our originator uses ADP metro for their payroll? we have an agreement in place with our customer, the originator, but do we have to have an agreement with ADP metro? Any advice is appreciated. Thanks.

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Operations Compliance
#657071 - 12/26/06 05:19 PM Re: NACHA Requirement- agreements comply123
RandomName Offline
Diamond Poster
Joined: May 2003
Posts: 1,373
Austin, TX
I only have a 2004 copy of the NACHA Operating Guidelines handy, but they state (in Section IV, Chapter I, Subsection B1, dealing with the ODFI's responsibilities):

"Agreements should also be entered into...between the Third-Party Service Provider and the ODFI."

This is important because Subsection D goes on to state:

"The NACHA Operating Rules require any Third-Party Service Provider...to conduct an annual audit of compliance". So you would want to make sure that your agreement stipulated that this be done.

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