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Preparing + Empowering Your ACH Originators for Nacha's 2026 Fraud Monitoring Requirements
Nacha's Fraud Monitoring Rules expand expectations for what financial institutions when it comes to non-consumer Originator oversight / With Phase 1 already in effect and Phase 2 enforcement beginning June 22, 2026, the question is no longer whether to act, but how.
Trevor Lain, JD
CEO & Attorney
Lexalign
Julie Goff, JD
VP, Head of Operations
Lexalign
What is Covered
Most FIs are aware of these changes. The challenge is how to operationalize compliance across a diverse portfolio of non-consumer Originators and Third-Party Senders, who each have different risk profiles, levels of sophistication, and readiness. How do you assess where they stand? How do you educate them on what’s expected? How do you build an oversight process that holds up under examination, not just once, but year after year?
In this session, Trevor Lain, JD, CEO, and Julie Goff, JD, Head of Operations at Lexalign, break down what the Rules actually require of Originators, ODFIs (oversight of Originators) and walk through a practical approach to getting your Originators to a state of continuous compliance.
What’s Covered:
- How to empower and educate Originators as partners in compliance and fraud monitoring
- What "verified by appropriate oversight" means in practice — and why attestations and questionnaires alone won't get you there
- How to assess Originator readiness across your portfolio, including "risk-based processes and procedures"
- What a scalable, repeatable annual review cycle looks like — one that produces audit-ready documentation
- A practical look at how Lexalign helps FIs operationalize Originator oversight at scale
Whether you’re well into your planning or still working through what these Rules require, this session is designed to give you clarity, practical strategies, and a path forward you can immediately set in motion.