Beginning January 1, 2021, National Automated Clearing House Association (NACHA) has a new rule on enforcing egregious violations. An “egregious violation” is a willful or reckless action by a Financial Institution, Originator, or Third-Party Sender, involving at least 500 entries or multiple entries totaling $500,000. The new rule gives NACHA the authority to better enforce rules related to egregious violations, including providing the ACH Enforcement Panel to determine 1) whether any violation is egregious, and 2) classify any egregious violations.
