This checklist is designed to help you prepare for the upcoming ACH rule changes and reduce the risk of fraud-related disruptions. Not every item will apply to every business, but following these steps will help maintain smooth, uninterrupted ACH processing.
Authorized Users & Access Control
- Review who is authorized to create, approve, and submit ACH files
- Ensure Internal Dual Control or review and approval processes are in place, where possible
- Remove access for former employees or users who no longer require ACH permissions
- Confirm login credentials and Daily ACH Company Limits align with ACH processing needs
Fraud Monitoring Rule Changes | Effective June 22, 2026
- Businesses that originate ACH entries will need documented, risk-based processes and procedures to help detect and respond to potential ACH fraud.
- Establish a verification process for new payees (call back strongly encouraged)
- Establish a verification process for changes to existing payment instructions (call back strongly encouraged)
- Use known, trusted contact information to verbally confirm changes
- Avoid relying solely on email for payment change requests
- Train staff to recognize common ACH fraud scenarios, including, but not limited to:
- Business Email Compromise (BEC): Impersonation of trusted employee, vendor, or partner
- Vendor or Payroll redirection scams: Fraudster convinces organization to change payment instructions
- Encourage a “STOP, THINK, VERIFY” approach for unusual or urgent requests
- Delay processing if verification cannot be completed
Monitoring & Documentation
- Maintain documented, risk-based processes and procedures for identifying and responding to ACH fraud
- Ensure procedures reflect how your business actually processes ACH activity
- Review and update processes and procedures at least annually
- Document how exceptions, confirmations, or escalations are or should be handled
Communication with the Bank
- Notify Grand Savings Bank in advance of expected changes, such as:
- Increased ACH Daily Limit needs or increased ACH volumes
- New payroll providers or vendors
- One-time or out of the ordinary transactions
- Keep ACH contact information current with bank so outreach can be handled quickly
- Email grandbusiness@grandsavingsbank.com or call 800.460.2070 with ACH or fraud-related questions
Final Check
- You know who internally is responsible for ACH oversight
- You understand what activity may prompt outreach from the bank
- You feel confident that your ACH process supports both efficiency and security