Complying with NACHA regulations can be challenging, particularly for smaller regional payroll companies and accounting firms. While larger payroll companies may view it as an expensive and inconvenient process, the burden falls even heavier on smaller players. Imagine the hundreds of thousands of CPA firms and bookkeeping firms across the country that offer payroll services to local clients. These firms heavily rely on third-party entities to facilitate money transfers.

However, with the tightening of operating rules and the reluctance of banks to engage in nested third-party sender relationships, these smaller companies may face obstacles and complexities.

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The Changing Landscape for Smaller Players

As NACHA focuses on identifying and clarifying roles and responsibilities within the money movement chain, banks are becoming more cautious about participating in nested relationships. This change makes it increasingly challenging for companies reliant on nested third-party sender setups to establish banking relationships. If these companies fail to secure banking partnerships, they will need to seek alternative solutions.

One option is to partner with a company that can eliminate the middleman and handle the money movement on their behalf. This strategic collaboration would alleviate the burden and responsibility faced by smaller players.

Ensuring Long-Term Compliance and Stability

For smaller regional payroll companies and accounting firms, adapting to the evolving landscape of NACHA compliance is crucial for long-term success. They need to assess their current operations and evaluate the feasibility of maintaining nested relationships or seek alternative approaches. Collaborating with a trusted third-party provider that specializes in NACHA compliance could be a viable solution. By partnering with such companies, smaller players can ensure they meet the necessary requirements and maintain stable banking relationships.

The Future of NACHA Compliance

Looking ahead, NACHA compliance is expected to remain a vital aspect of conducting business efficiently and securely. As the operating rules continue to evolve, employers, payroll companies, and accounting firms must stay informed and adapt accordingly. The shift away from nested third-party sender relationships underscores the importance of direct authorization and transparency within the money movement process.

Navigating the Compliance Landscape

To navigate the compliance landscape effectively, employers and entities involved in money transactions should stay up to date with NACHA’s operating rules and guidelines. Regularly reviewing contracts, such as origination agreements and ACH authorization forms, is essential. Promptly responding to requests for updated forms and agreements from payroll companies demonstrates a commitment to compliance and smooth operations.


Navigating NACHA compliance poses unique challenges for smaller regional payroll companies and accounting firms that rely on nested third-party sender relationships. As the banking landscape evolves and operating rules become more stringent, establishing direct authorization and finding alternative solutions becomes increasingly important.

By proactively addressing compliance requirements, seeking reliable partnerships, and embracing industry changes, smaller players can ensure stability, meet their obligations, and continue to serve their clients effectively in the ever-changing world of NACHA compliance.

Learn more about partnering with Asure to provide payroll services to your clients.

Watch our video, NACHA, Bank Secrecy Act, Money Transmitter Law: What Businesses Must Know

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