What is a Sending Point ?
NACHA RULES §§2.2, 1.9 Sending Point
An entry containing the routing number of an ODFI which is transmitted to an ACH Operator by a Sending Point used by the ODFI to transmit entries to an ACH Operator on its behalf is transmitted pursuant to an agreement entered into between the ODFI an the Sending Point to transmit the entry.
The ODFI and any third-party service provider that has acted on behalf of the ODFI with regard to the
entry are in compliance with the audit requirements set forth in Appendix Eight (Rule Compliance Audit
Requirements), which provide for an annual audit of compliance with these rules.
18.104.22.168 Point-of-Purchase Entries
For a POP entry, the source documents provided to the Originator for use in obtaining the Receiver’s
routing number, account number, and check serial number for the initiation of such an entry is
(1) returned voided to the Receiver after use by the originator, and
(2) Has not been provided by the Receiver for use in any prior POP entry
[22.214.171.124 Telephone-Initiated Entries
For each TEL entry, the Originator
(1) has employed commercially reasonable procedures to verify the identity of the Receiver, and
(2) has utilized commercially reasonable procedures to verify that routing numbers are valid.]
Notwithstanding anything in these rules to be contrary to the warranties contained within subsection 2.2.1
(Warranties) and the requirements of subsection 2.1.2 (Receiver Authorization and Agreement) do not apply to the goods or services to which the entry relates.
2.2.3 Liability for Breach of Warranty
Each ODFI breaching any of the preceding warranties shall indemnify each RDFI, ACH Operator, and
Association from and against any and all claim, demand, loss, liability, or expense, including attorneys’ fees and costs, that result directly or indirectly from the breach of warranty or the debiting or crediting of the entry to the Receiver’s account. This indemnity includes, without limitation, any claim, demand, loss, liability, or expense based on the ground that the debiting of an entry to an account resulted, either directly or indirectly, in the return of one or more items or entries of the Receiver due to insufficient funds. This indemnity also includes, in the case of a Consumer Account, without limitation, any claim, demand, loss, liability, or expense based on the ground that the failure of the ODFI to comply with any provision of these rules resulted, either directly or indirectly, in the violation by an RDFI of the Federal Electronic Fund Transfer Act or Federal Reserve Board Regulation E.
2.2.4 Sending Points
An ODFI shall be deemed to have made the warranties of subsection 2.2.1 (Warranties) for each entry
described in subsection 126.96.36.199 (Sending Points) whether or not the Sending Point was authorized by the ODFI to transmit the entry.