Nacha compliance
Last updated: September 2, 2026
Embank Financial originates ACH entries in accordance with the Nacha Operating Rules and applicable law. This page is a general overview of how we approach compliance; the current Nacha Operating Rules and applicable Federal Reserve requirements govern.
The ACH network and our role
Embank Financial is a payment technology company, not a bank. ACH entries are originated through relationships with sponsoring financial institutions that act as the Originating Depository Financial Institution (ODFI). Every entry transmitted through the network is subject to the Nacha Operating Rules, which bind all participants and govern authorization, formatting, warranties, return rights and timeframes.
Authorization
Each ACH entry must be authorized by the Receiver in the manner required for its Standard Entry Class (SEC) code — for example PPD, CCD, WEB or TEL. Originators are responsible for obtaining authorization in the required form, retaining evidence of that authorization for the period the Rules require, and providing it on request. We support originators in meeting these obligations.
Account validation and data protection
For WEB debit entries, the Nacha Operating Rules require a commercially reasonable method of validating the account to which an entry is sent. We apply account validation and screening consistent with those requirements. Account and routing numbers are protected in transit and at rest, and payment credentials are handled through tokenization so the underlying numbers are not exposed unnecessarily.
Risk management and monitoring
We monitor origination activity and return rates against the thresholds Nacha establishes — currently 0.5% for unauthorized debit returns, 3.0% for administrative returns, and 15% overall — apply exposure limits, and review activity for indicators of unauthorized or improper use. Origination may be paused or limited where activity approaches these thresholds or where risk indicators warrant.
Returns and notifications of change
Returns and notifications of change (NOCs) are processed within the timeframes set by the Nacha Operating Rules. Settlement is not final in every case: an entry remains subject to return within the timeframe applicable to the return reason code, and a notification of change may correct the account or routing information carried on an entry.
Consumer protections and unauthorized entries
Consumers have rights under the Nacha Operating Rules and applicable law, including the right to have an unauthorized debit returned within the applicable timeframe. If you believe an entry to your account was not authorized, contact your financial institution promptly so the entry can be returned within the required window.
Reporting a concern
To report a suspected unauthorized transaction or a compliance concern involving Embank Financial, contact us at [email protected].
Important note
This page summarizes complex requirements for general information only and may be simplified or become out of date. It is not legal or compliance advice. The current published Nacha Operating Rules and applicable Federal Reserve and legal requirements govern in all cases.