In a recent article, we explained what the NACHA rule change coming in June 2026 means for community banks — including the shift to personal injury liability and why monitoring at the originator level is now the standard.
The natural follow-up question: what does originator-level monitoring actually look like in practice?
Here are three capabilities in SAM’s ACH module that directly address what the new rules require.
1. Tracking the Originating Bank — Not Just the Originator ID
Most ACH monitoring systems identify transactions by the originator ID, which is almost always a tax ID number. The problem is that a single tax ID can appear at multiple banks. Fraudsters know this. They open accounts at several institutions using the same tax ID and send transactions that look routine to systems that only check the originator ID.
SAM tracks both the originator ID and the originating bank (the ODFI). When a familiar originator ID shows up from an unfamiliar bank, SAM flags it. This is the specific blind spot the new NACHA rules are designed to close — and it’s one that core systems and many standalone AML platforms don’t cover.
2. First-Time Originator Alerts
Under the new rules, the highest-risk transaction isn’t necessarily the largest one. It’s the one from an originator that has never sent a transaction to your customer before.
Each day, when SAM processes your incoming and outgoing ACH files, it identifies every transaction where the originator has no prior history with that customer. These first-time originator transactions are surfaced for same-day review — with particular emphasis on incoming commercial debits, where the return window is just two business days.
3. Return Rate Monitoring by Originator
NACHA requires banks to monitor ACH return rates for every customer that originates transactions through the bank. If an originator’s return rate exceeds 1% for certain return codes, the bank must intervene. Above 2%, the bank is required to close the account.
SAM tracks return totals by originator across rolling 30-, 60-, and 90-day windows — broken out by return type — so your compliance team can identify which originators are approaching or exceeding the thresholds before an examiner asks the question.
What These Three Have in Common
Each of these capabilities answers a question that core systems aren’t built to ask. Core systems monitor dollar amounts per customer. The June 2026 NACHA rules require monitoring by originator, by originating bank, and by return pattern. That’s a fundamentally different kind of analysis.
SAM has been performing this analysis for over fifteen years — originally built to meet Florida’s protection-of-the-elderly financial laws, which required originator-level monitoring long before NACHA adopted it nationally. The result is some of the most advanced ACH monitoring on the market, with straightforward reports and straightforward pricing.
Find out more about ACH monitoring using the Suspicious Activity Monitor
If you’d like to see how these features work with your bank’s ACH data, contact us to schedule a walkthrough or start a 30-day free trial.