Rules Enforcement Exercise

Question 1

What is the purpose of the ACH Fines and Enforcement?

Answer 1

It is the intent of this enforcement mechanism to maintain the quality of ACH services and the satisfaction of Participating DFIs and their customers by ensuring compliance by DFIs with the Nacha Operating Rules and reducing the risks to parities by limiting the number of Unauthorized ACH Entries.

Question 2

The Rules Enforcement Panel may direct an ODFI to suspend the Originator or Third-Party Sender from originating if it has determined that there is a ________ Rules Violation.

Answer 2

Class 3

Question 3

An ODFI that is unable to provide Nacha with a copy of a requested ACH Audit report will be considered as a _________ Rules Violation.

Answer 3

Class 2

Question 4

After the fourth Rules Violation of failure to comply with an NOC, an ODFI is assessed a $100,000 fine by Nacha for a Class 2 Rules Violation. The ODFI made every attempt to let its Originator know it was the Originator’s obligation to correct the payment information; however, the Originator continued to send the entry incorrectly. The ODFI is pursuing legal action toward the Originator to recoup the $100,000 fine. The dispute is interpreted according to the provisions of ______________

Answer 4

State contract law.

Question 5

What is the maximum fine for a 3rd recurrence of a Class 1 Rules Violation?

Answer 5

$5,000

Question 6

The maximum fine for a Class 3 Rules Violation

Answer 6

$500,000 per month until resolved

Question 7

A fourth recurrence of a rules violation is a Class ______ violation.

Answer 7

2

Question 8

Who may suspend an Originator if there is a Class 3 violation?

Answer 8

The Rules Enforcement Panel