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Bank (NACHA) File Payment Processing Policy

PBI's procedures and controls for processing client vendor payments through the Bank (NACHA) file process — including how vendor banking information must be collected and validated.

FieldValue
OwnerJonah Dellasega, Accounts Payable Senior Manager
DepartmentAccounts Payable
Effective dateMay 1, 2025
ScopeProcessing client payments to vendors using the Bank (NACHA) file process within Intacct and clients' banking institutions. Covers secure handling, validation, and documentation of sensitive banking information, plus onboarding a new client's bank file format.
SourceAccounts Payable Department/3. Payment Processing/NACHA (Bank File) Payment Processing Policy.docx
AuditQuarterly Accounts Payable audit program

This is a policy, not a how-to guide. The controls below are audited quarterly. Deviating from them is a compliance issue, not a matter of preference.

Definitions

TermMeaning
ACH (Automated Clearing House)A network used for electronically moving money between bank accounts.
Bank (NACHA) fileA standardized file format used to initiate ACH payments.
Banking informationBank name, routing number, account number, account type, and account holder name.

Responsibilities

RoleResponsibility
Accounts Payable Senior ManagerDefines the policy, ensures adherence, and modifies the policy when needed.
Accounts Payable ProcessorPrepares and validates NACHA files.
Client ManagerVerifies accuracy and completeness of payment information before submission to the bank.

Onboarding a client's bank file format

Complete this research before implementing ACH payments by bank file for a new client. Skipping it produces a file the bank silently rejects.

1
[Client Manager] Contact the client's bank

When onboarding a new client or planning to implement ACH payments via bank file, contact the client's bank relationship manager or treasury support team to ask about ACH capabilities and the required file format — for example Standard NACHA, CTX, CCD, or a bank-specific format.

2
[Client Manager] Request the bank's specifications

Request a sample ACH file layout, technical specification document, or implementation guide from the bank. This contains the required structure, field mappings, and delimiter or spacing rules.

3
[Client Manager] Review with the PBI Intacct admin

Provide the bank's specification to PBI's Intacct Administrator to determine what format customization is required within Intacct.

4
Customize the Intacct export template

If the client's bank requires a non-standard NACHA format, work with the Intacct Admin or Sage Intacct support to create or modify a custom bank file template under Cash Management → Payment Formats.

5
Validate a test file

Upload a sample bank file to the client's bank portal — in a non-processing or test environment if one is available — to validate that the file is accepted. Troubleshoot errors with the bank and Intacct support as needed.

6
Document the format requirements

Once finalized, upload a copy of the bank's ACH specification and a sample accepted file to the client's SharePoint folder under ACH File Specs, for future reference and audits.

Collecting vendor banking information

Vendor banking details are ideally submitted through the online Microsoft Form managed by PBI: bit.ly/achenroll.

In other cases, details may arrive by email, paper documentation, or — rarely — a phone call.

PBI and clients should actively steer vendors to the Microsoft Form. It provides better security and creates an audit trail of submissions. Email and physical documents containing banking information are heavily discouraged.

Validating banking information

All newly submitted or updated banking information must be validated before vendor master data is updated.

1
[Client Manager] Call the vendor to confirm

Call the vendor and confirm the banking information verbally.

Whenever possible, confirmation should come from a different person than the one who submitted the information. This is the control that defends against a compromised vendor email account.

2
[Client Manager] Update the vendor master data

Once confirmed, update the payment type and banking information in the vendor master data within Intacct. Set the Vendor Type in Intacct to Bank File.

3
[Client Manager] Document the validation

Record the following in the vendor master data in Intacct:

  • The validation date
  • The vendor contact who confirmed
  • The responsible PBI employee

Expected outcome: the vendor record shows Bank File type, current banking details, and a dated validation note naming both parties.

If a vendor cannot confirm their banking information, treat the submission as potentially fraudulent. The client manager must immediately inform both the vendor and PBI's client of a possible attempt.

Preparing and reviewing the NACHA file

1
[AP Processor] Select the invoices and notify

Select the invoices to be paid by NACHA (Bank File) in Intacct, then notify the client manager that the payments have been selected.

2
[Client Manager] Generate and save the bank file

Log in to Intacct and generate the bank file in the format required by the client's bank.

Save the file in the Accounting Managers SharePoint under the ACH Payment File folder, in the client's subfolder.

3
[Client Manager] Load the file at the bank

Log in to the client's bank, navigate to the payment section, and initiate a payment by loading the bank file downloaded from Intacct.

4
[Client Manager] Reconcile before releasing

Confirm the payment vendors and amounts line up with what is listed in Intacct. Only once everything reconciles can the payment be processed.

This review is the last point at which an incorrect or fraudulent payment can be stopped. Do not treat it as a formality.

5
[Client Manager] Authenticate and submit

The bank asks for password validation plus a token code, received either from a hard token issued by the bank or a soft token on the client manager's cell phone.

Expected outcome: the bank accepts the file and the payments are released for settlement.

Policy audit

This policy is audited through the quarterly Accounts Payable audit program, which tests the controls above for collection, verification, and documentation of vendors' sensitive banking information.