ACH Rule Spotlight: ODFI Requirements for Providing Originator Contact Details
Published on November 5, 2025
AUTHOR
Eric Wester, AAP, AFPP, APRP, NCP
Director of Member Services
Our team at UMACHA has noticed a significant increase in member inquiries about whether an Originating Depository Financial Institution (ODFI) is required to provide an Originator’s contact information, such as a phone number or email address, to a Receiving Depository Financial Institution (RDFI) upon request. In many cases, ODFIs routinely share this information, sometimes through automated tools that allow RDFIs to obtain Originator details after supplying the corresponding Company ID. However, this rise in inquiries raises an important question: while many ODFIs choose to provide this information, are they actually required to do so under the Nacha Operating Rules?
The short answer is that, in most cases, an ODFI is not required to provide an Originator’s contact information to an RDFI. However, the specific facts and circumstances surrounding the ACH Entry play an important role in determining what is required. Key considerations include whether the Entry was sent to a consumer or non-consumer Receiver’s account and the Standard Entry Class (SEC) Code used for the transaction. Understanding these factors helps clarify when providing Originator information may be appropriate or necessary and what options an ODFI has when responding to an RDFI’s request.
Entries to a Consumer Receiver
An ODFI is not obligated to provide an Originator’s contact information, such as a phone number or email address, in connection with inquiries related to an Entry posted to a consumer Receiver’s account. Instead, when an RDFI or its consumer Receiver seeks additional information about a specific Entry, the RDFI may submit a written request for proof of authorization to the ODFI.
Article Two, Subsection 2.3.2.7 (Retention and Provision of the Record of Authorization) outlines the ODFI’s responsibilities in these cases, including the available response options once the RDFI’s written request has been received.
Specifically, the Nacha Operating Rules state, “Upon receipt of an RDFI’s written request, the ODFI must:
(1) provide the original, copy, or other accurate Record of the Receiver’s authorization, including, with regard to a Standing Authorization, evidence of the Receiver’s affirmative action to initiate a Subsequent Entry in accordance with the terms of the Standing Authorization, to the RDFI within ten Banking Days without charge.
OR
(2) confirm to the RDFI in writing the ODFI’s agreement to accept the Return of the Entry that is the subject of the RDFI’s inquiry at any time within ten Banking Days of providing the confirmation to the RDFI, without regard to any other time limits on Returns under these Rules.
Where the ODFI has accepted, or has agreed to accept, the Return Entry, and the RDFI subsequently still makes a written request for evidence of authorization of the Entry, the ODFI must provide the original, copy, or other accurate Record to the RDFI within ten Banking Days of the RDFI’s written subsequent request to the ODFI for a copy of the Receiver’s authorization.”
Entries to a Non-Consumer Receiver
When an RDFI submits a written request for proof of authorization related to a CCD, CTX, or Inbound IAT Entry to a non-consumer Receiver’s account, providing the Originator’s contact information is one possible response an ODFI may choose to provide. However, it is not the only option available. The ODFI may instead elect to respond in a different manner, as permitted by the Nacha Operating Rules.
Article Two, Subsection 2.3.3.3 (Provision of the Record of Authorization) of the Rules outlines the ODFI’s obligations and the acceptable response options in these circumstances, giving ODFIs flexibility in determining how to appropriately respond to the RDFI’s request.
Specifically, the Nacha Operating Rules state, “Within ten Banking Days of receipt of an RDFI’s written request for evidence of authorization of the Entry, the ODFI must either:
(1) provide an accurate record evidencing the Receiver’s authorization, or
(2) provide the contact information for the Originator that, at a minimum, includes (i) the Originator’s name, and (ii) the Originator’s phone number or email address for inquiries regarding authorization of Entries, or
(3) confirm in writing the ODFI’s agreement to accept the Return of the Entry that is the subject of the RDFI’s inquiry at any time within ten Banking Days of providing the confirmation to the RDFI, without regard to any other time limits on Returns under these Rules.
Where the ODFI has accepted, or has agreed to accept, the Return Entry, and the RDFI subsequently still makes a written request for evidence of authorization of the Entry, the ODFI must provide to the RDFI either an accurate Record evidencing the Receiver’s authorization or the Originator’s contact information within ten Banking Days of the RDFI’s subsequent written request.”
UMACHA is Here to Help
UMACHA members have access to our library of complimentary sample documents, including a sample written request for proof of authorization that can be used by an RDFI when submitting a request to an ODFI.
If you have questions about the process of submitting a written request for proof of authorization to an ODFI—or any other payment-related question—please don’t hesitate to reach out to UMACHA for support. Our team is here to help guide you through the process and provide clarification as needed. Remember, personalized support and education are part of the valuable benefits included with your UMACHA membership.
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