From a Checkbox to a Differentiator: Redefining ACH Fraud Monitoring

Last year, the treasurer’s office in Warren County, New York sent $3.3 million to what it believed was the county’s roadwork and maintenance contractor. It was not—the payments were instead routed to a fraudulent account. Because the county had recently switched from paper checks to ACH, the treasurer’s office had no account verification policies in place to prevent what turned out to be a textbook case of fraud.

While the damage in Warren County represents the upper end of the spectrum, this incident is far from an outlier. It underscores the importance of implementing ACH protections, which many organizations already have in place. Too often, however, these measures are treated as a set-it-and-forget-it solution or merely a compliance checkbox.

In a recent PaymentsJournal podcast, John Gordon, CEO of ValidiFI, and Suzanne Sando, Lead Fraud Management Analyst at Javelin Strategy & Research, discussed how robust ACH fraud monitoring controls can do more than satisfy regulatory obligations—they can act as a proactive risk prevention mechanism. This is essential to combat the growing prevalence and complexity of fraud.

The Importance of Trust

The compliance aspect of ACH fraud monitoring is partly driven by the latest version of the WEB debit rule, instituted by Nacha—the organization that governs the ACH network. Nacha’s enhanced fraud monitoring requirements raise expectations for all participants in the ACH ecosystem.

“It increases the bar to say that we’re not just checking the validity of the account, but we’re also doing fraud checks,” Gordon said. “It creates an opportunity for financial service providers to identify fraud and to look at the potential risk associated with a consumer.”

“It moves beyond compliance for compliance’s sake, which creates a lot of opportunities for financial service providers to not only identify and reduce fraud, but to put consumers in the right products that create mutually beneficial paths for them,” he said.

Finding the right fit with customers has become more challenging in the digital era, where consumers have more options than ever and increasingly expect efficiency in every interaction. As a result, consumers often choose the path of least resistance when selecting a financial institution.

These factors place institutions in a precarious position: they must balance security with customer expectations, both of which significantly impact retention.

“The importance of consumer trust cannot be overstated,” Sando said. “We’re finding that when consumers have experiences with fraud or scams on a particular account—whether it’s a traditional financial account like your checking or savings or a merchant account—if they’ve experienced any sort of suspicious activity or fraud and scams, they’re much more likely these days to close an account where the fraud occurred and move somewhere else.”

Stepping Up Authentication

Given the risk of attrition, account onboarding and authentication have become critical stages in the customer experience. One key challenge arises from misapplied friction, where every user is forced to undergo the same verification process regardless of risk profile.

“Our belief is there’s enough value in customer data that it can be managed through step-up authentication, that you are injecting friction where friction is warranted based on the risk signals that consumers have in concert with their profiles—whether that be their bank account, their payment transactions, or their credit scores,” Gordon said.

“There are a number of different ways to end up at the right answer so that you’re facilitating a flow where the consumers stay in the process and you are fast tracking your low-risk consumers and putting obstacles in place where they should be,” he said.

This process can be optimized by leveraging the richer data available in a validated account. Institutions can go further by authenticating the account, confirming that the applicant’s name matches the account owner’s—allowing for a more targeted, efficient approach.

Implementing these measures early in the process is critical for fraud prevention and enables a customized experience, reducing the verification burden on the institution.

For example, if a consumer opts out during onboarding due to friction triggered by their financial profile, the institution avoids a potentially difficult credit decision. Conversely, highly qualified consumers can be fast-tracked, improving both the experience and conversion rates.

Scouring Alternative Data

Although authentication is vital, it is increasingly challenging under the current credit scoring system. Last year, traditional scoring methodologies eliminated medical debt—a significant portion of consumer credit—from scores. While this change reshapes scoring, it does not remove the underlying debt burden.

Additionally, consumers now maintain more financial relationships than ever, including accounts at traditional banks, digital-first banks, and fintechs. Many of these relationships are undisclosed, complicating accurate assessments of creditworthiness.

“It becomes incumbent upon financial service providers to look at alternative data in a way that they can derive value out of it,” Gordon said. “We believe the consumers’ bank behavior, their payment success rates, and the velocity with which their PII elements change are all clues that will lead you to have a more accurate picture of that consumer—what they can afford and their creditworthiness.”

“When we factor in the way that consumers acquire credit today versus the way they did in 1989 when the FICO score was created, they’re wildly different,” he said. “The traditional scoring methodologies haven’t kept pace with the way consumers are acquiring credit now. We see scenarios where consumers apply with a clean bank account only to subsequently change to a neobank account or some other bank account that they’re utilizing to enact what equates to first party fraud.”

Palatable to All Parties

These challenges have driven the emergence of data-driven treatment strategies, where financial service providers leverage shared industry data. This intelligence provides critical insights into connections between consumers, accounts, identities, and performance metrics.

Such knowledge enhances underwriting, creating a scenario where a consumer’s application experience is guided by both their inputs and industry knowledge of past activity. However, these strategies must always be aligned with the institution’s broader objectives.

“We have a client that we work with that does account-to-account payments tied to loyalty cards,” Gordon said. “Their exposure in that scenario is fairly limited, they want as much acceptance as they can possibly get. Conversely, we have some clients who are doing large dollar distributions, and it is not too much to ask for someone to credential into a bank account and we’re talking about the potential for five- and six-figure disbursements.”

“It’s difficult to ensure that you’re keeping down the cost of doing business, the fraud losses, and ultimately the cost of credit,” he said. “When you marry the authentication process to the use case, you end up with a lot better solution that’s more palatable to all parties.”

Confidently and Compliantly

Developing strategies and implementing fraud management measures is imperative, as new and potent fraud variant emerge daily. The most effective defense is sharing information and leveraging a risk intelligence provider to help chart the way forward.

“It’s finding a solutions provider that is flexible and can adjust and be agile in the same way that we find fraudsters are agile with technology and how they can use it against consumers,” Sando said. “It’s also about recognizing the fact that consumers are not all the same, it’s not one-size-fits-all. It’s about having that solution provider that can help you figure out how we navigate each individual case to make sure that it’s optimized for every single customer that comes through the system.”

These solutions help organizations stay ahead of escalating fraud threats and maintain compliance with regulations like Nacha’s rule enhancements. But that’s just the beginning.

“There is a lot of opportunity beyond compliance in account verification and authentication,” Gordon said. “What we see is that not only will more of your payments clear, but there are certain attributes and thresholds that , when crossed, significantly improve performance. Meaning, you’ve verified the account, the account has a certain history, and it doesn’t indicate any of the negative attribution that we often see compounded by a name match. You have the ability to operate confidently and compliantly in a way that you probably aren’t enjoying at present.”