Small FIs & the New NACHA Fraud Monitoring Rules (Phase 1)

In this episode of Fraud Forward (formerly Banking on Fraudology), host Hailey Windham tackles a critical issue facing financial institutions: NACHA’s upcoming ACH fraud monitoring requirements.

Hailey breaks down the upcoming rule changes with a clear, practical lens, especially for small banks and credit unions preparing for compliance. She walks listeners through NACHA’s two-phase implementation, explaining how institutions can get ready for the March 2026 deadline without overspending or overengineering their programs.

Throughout the episode, Hailey clarifies key concepts such as “false pretenses” and the industry shift away from “commercially reasonable detection systems” toward more flexible, risk-based processes. 

You’ll hear actionable guidance on:

• Conducting ACH fraud risk assessments
• Establishing transaction baselines
• Designing effective monitoring and response procedures
• Writing policies and managing annual reviews

The episode also dives into vendor selection, highlighting common sales pitches to watch out for and smart, strategic questions to ask potential partners. Above all, Hailey emphasizes the importance of tailoring fraud monitoring to an institution’s specific role, risk profile, and resources.

You’ll get a clear action plan for compliance and a stronger understanding of how to build sustainable ACH fraud defenses in a changing regulatory landscape. This is a must-listen for any fraud fighter looking to stay ahead of the curve. Learn more about NACHA’s ACH Fraud Monitoring Rule (Phase 1) here.