Compliance with Third-Party Sender Registration Rule – Time is Running Out!


  • Identify ways in which the ODFI can perform due diligence to determine “if” they have a Third-Party Sender relationship
  • Define the requirements for the ODFI to provide a limited set of initial, basic registration information for each Third-Party Sender 
  • List the additional pieces of information on TPS that may be required by NACHA 
  • Identify the extra implementation period, provided by NACHA to submit initial registration information (past Sept 29, 2017)
  • Explain how registration is also required for the ODFI to provide statements that they have no Third-Party Sender customers
  • ACH Operations staff
  • Compliance Officers (Auditors)
  • ACH Managers
  • Third-Party Senders
  • Electronic Payments Professionals
  • AAP’s – keeping up with changes in ACH Rules - to earn AAP Continuing Education Credits
  • Anyone who wishes to enhance their knowledge of new rules

Topic Background

A NEW Rule was recently implemented (effective Sept 29, 2017) and will require Originating Depository Financial Institutions (ODFIs) to identify and register their Third-Party Sender customers with NACHA. The registration process will promote consistent customer due diligence among all ODFIs, and serve as a tool to support NACHA’s continuing efforts to maintain ACH Network quality. 

In order to understand the impact, this will make on the different participants (specifically Third Parties) – the most difficult task is the need to identify the “Third-Party Sender” – extremely detailed examples will be used to help with this identification (due diligence) process.

Donna K Olheiser, AAP, is the vice president of Education Services and founder of Dynamic Mastership, LLC.; and holds the Accredited ACH Professional (AAP) designation (achieved in 2004). She is an enthusiastic and energetic Certified Master Trainer with over 14 years’ training experience. She has designed and facilitated over 100 training sessions each year with her expertise being the rules for companies and financial institutions when processing electronic (specifically ACH) payments, then scheduling the events to facilitate and deliver the material through a variety of venues (webinars, teleseminars, in-person workshops, including regional and national conferences). 

Her extensive knowledge, enthusiasm and passion for transferring payment processing knowledge using the adult learning theory is remarkable and has helped many payment professionals perform daily operational tasks including exception processing while remaining compliant with the NACHA Operating Rules. She uses scenarios and examples to bring the learning home, easy to comprehend and apply to real-life day-to-day ACH processing. Ms. Olheiser’s ability to engage the learner through the entire training event helps the adult learner apply what they’ve learned during and after each training session.

Donna has over 24 years of experience in the financial services industry which includes 9 years’ experience as the education service director at a Regional Payments Association (RPA), where she managed and facilitated the entire education program for nearly 800 financial institution members. Prior to that, Ms. Olheiser spent 14 years in various departments with the Federal Reserve Bank of Minneapolis, including the internal educator for FedACH Central Operations.

Third-Parties in ACH performs different functions which determine their role in the ACH network. A NEW Rule now requires registration with NACHA to identify any Third-Party Senders! Even if the ODFI does NOT have a Third-Party Sender relationship, they are still required to register their “non-TPS relationship”

What do these Third-Parties do for either the financial institution (ODFI/RDFI) or the company (Originator) and how does this affect the role they play in the ACH network? First, due diligence must be done by the ODFI to answer this question - are you in a Third-Party Sender relationship?

Determined by this “role they play” makes them, and the financial institution they do business with obligated to adhere to responsibilities and the Rules when processing ACH Payments. The ODFI will be required to register any Third-Party Sender (and nested Third-Party Senders) for whomever they are doing any type of ACH business with them.

In this 90-minute session, the different types of Third-Parties will be addressed. Third-Party Service Provider and Third-Party Sender and the difference between the two will be identified to help the ODFI in determining if they have a Third-Party Sender relationship. The ODFI is required, with this new Rule, to register any Third-Party Sender relationship or even if there is no relationship, registration is still necessary. Attend this session to hear suggestions on how the ODFI can perform their due diligence to determine whether they have a Third-Party Sender relationship and register with NACHA accordingly beginning Sept 29, 2017.

  • $135.00