Webinar Recap: 2026 ACH Fraud Monitoring: What Financial Institutions Need To Know
Read Time 4 mins | Written by: Karly Field
Thank you for your interest in our recent Beyond the Vault webinar:
2026 ACH Fraud Monitoring: What Financial Institutions Need to Know
If you were able to join us live, we appreciate your time. If not, we’ve made the full recording available below.
During the session, we covered:
• Key changes in the 2026 Nacha ACH Fraud Monitoring rules
• Expanded responsibilities for ODFIs, RDFIs, and third parties
• What “risk-based monitoring” means in practice
• Practical steps financial institutions can take now to prepare
Additional Resources:
📄 Webinar slide deck: PowerPoint File
📘 ACH monitoring preparation checklist: Checklist Link
🔎 ODFI Operations and ACH Origination Workshop: Register Here
The 2026 changes will impact monitoring expectations more broadly than many institutions anticipate. If you would like to discuss how these updates apply specifically to your institution, we’re happy to schedule a demo and brief conversation.
Remember if you schedule a demo prior to March 15, 2026 and move forward with a contract, you will receive a 20% discount on pricing.\
Follow Up Question!
If the bank misses something, manual or using software, does that make us liable? The bank can't catch everything. This seems like the customer has no responsibility to report fraud to the bank. Reg E puts the reporting responsibility to the customer. Does NACHA supersede Reg E??
- Consumer Reporting Responsibility Remains: Under Regulation E, consumers do have responsibility to report fraud and unauthorized transfers within specific timeframes (2 business days for lost/stolen cards, 60 days for unauthorized transfers on statements).
- Bank Liability for Missing Fraud: If your bank misses fraud detection (whether manual or automated), this does not automatically make you liable for consumer losses. Consumer liability is determined solely by the timeliness of their reporting, not by the bank's detection capabilities.
- Liability Limits Are Fixed: Consumer liability cannot exceed:
- $50 if reported within 2 business days of learning of loss/theft
- $500 if reported after 2 business days but before 60 days
- Unlimited only for transfers occurring after 60 days from statement date (if the bank can prove timely notice would have prevented the loss)
- Consumer Negligence Cannot Increase Liability: Even if a consumer acts negligently (like writing their PIN on their card), this cannot be used to impose greater liability than Regulation E permits.
- 12 CFR § 1005.6 - Consumer Liability
- 12 CFR § 205.6 - Consumer Liability (Legacy)
- CFPB Supervisory Highlights, Fall 2014 - Consumer Liability for Unauthorized Transfers
- CFPB Supervisory Highlights, Issue 37 (Winter 2024) - ACH Transaction Compliance
- CFPB Enforcement Action: Early Warning Services, LLC; Bank of America, N.A.; JPMorgan Chase Bank, N.A.; Wells Fargo Bank, N.A (December 20, 2024)