Third-Party Senders Should be Asking Their Auditors Lots of Questions

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Building and maintaining a strong Third-Party Sender program involves a lot of moving parts, so a little expert advice can go a long way toward ensuring success. Two TPS experts recently partnered on Nacha's Payments SmartCast podcast to share their thoughts on some best practices, starting with your annual audit.

"Ask your auditor really, really important questions to say, 'What have you learned in the field? What have you learned from other Third-Party Senders? What is the book not telling me?" said Milan Malkani, Founder of dhango, a payments infrastructure company providing white-labeled middleware for payments platforms acting as third-party senders. dhango is also a Nacha Preferred Partner.

Malkani said when implementing a Nacha Rule, "it's hard to translate that to the real world sometimes, and you kind of need somebody that's been there, done that before, that can translate that for you in the real world."

Jordan Bennett, Nacha Senior Director, ACH Network Risk Management, agreed, saying that beyond ensuring compliance with the Nacha Rules, TPSs should "turn that audit into a learning experience."

"We want people to comply with the Rules, of course. But what we really want is for people to learn from this experience. We want people to talk to their auditors," said Bennett.

Malkani urged TPSs to automate their ability to send and receive credit and debit files. "People constantly underestimate the sensitivity of the data that's in those files, and so you want automation around that. You just don't want to introduce human error," he said.

Much more was discussed, and you can listen to the complete podcast below.