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Dilly Labs

What's the Dilly-o with fraud detection: a buyer's guide for credit unions

Nacha's Phase 2 fraud monitoring rule took effect June 19, 2026, a federal holiday, so the working date was Monday, June 22.1 Phase 1 applied to receiving depository financial institutions (RDFIs) with annual ACH receipt volume of 10 million or more in 2023.2 Phase 2 extends the rule to all other RDFIs.3 So if your credit union receives ACH credits for members, we'd confirm you have written processes to spot the fraudulent ones.

The Dilly-o

Nacha says its rules are neutral on the methods or technologies used to spot fraudulent credits.4 So we'd start with what your digital banking platform and core already include, write down how you use it, and buy a specialist tool only for the gap your own loss data shows. Think of it as a moat with several rings: one tool rarely covers logins, checks, ACH and scams at once.

How we'd size up a vendor

  1. Coverage - which channels does the tool watch: logins, ACH credits, checks, card or calls?
  2. Fit - is it already connected to your digital banking platform and your core, or does it need a custom build? Ask the vendor to show you how it connects to your core today.
  3. Evidence - does it keep an audit trail of each alert and the action taken on it? Ask to see a sample record before you sign.
  4. Pricing model - do you pay per event, per alert, per seat or a flat fee? Ask the vendor to price your real login and transaction volume before you sign.

What changed this year

On October 1, 2024, Nacha defined "false pretenses," codified return code R17 for suspected fraud and allowed R06 for any reason.5 From April 1, 2025, an RDFI had to answer a sending institution's R06 request within ten banking days.6 From March 20, 2026, originators must label wage credits "PAYROLL" and e-commerce debits "PURCHASE".78 You must also review and update your monitoring procedures at least once a year.9

Will it work with your systems?

Your digital banking platform may already carry fraud tools. On November 4, 2026, TEN Credit Union was reported to have picked Bankjoy, whose platform includes its FraudSense real-time fraud system.10 Lumin Digital announced an identity security partnership with ID Dataweb on October 15, 2024.11 Mitek is listed as an Alkami partner integration for check fraud detection.C On the core side, Alogent is a Corelation Keystone preferred partner and is listed in Jack Henry's network for Symitar credit unions.C Narmi is KeyBridge certified for Keystone and listed for Symitar, and Unit21 is a Keystone preferred partner for collections and risk.C Ask your provider which fraud partners are live today, what data they receive, and who owns the alert when one fires.

What other credit unions did

Suncoast Credit Union, with $20.7 billion in assets, moved onto Alloy for identity and fraud decisions.12 Raiz Federal Credit Union reported stopping more than $286,000 in fraud in its first year with BioCatch and other measures.13 MSUFCU, a Michigan credit union, launched Pindrop's Passport and Protect products in its call center in August 2024.14

What your examiner will ask

NCUA's 2026 priorities look for strong monitoring and alerts on unusual activity, plus periodic updates and testing of fraud safeguards.1516 The FFIEC authentication guidance, which counts credit union members as customers, calls for layered security.1718 It also calls for monitoring, logging and reporting of activity to identify and track unauthorized access.19 For the vendor, NCUA says third-party contracts should address service level agreements, performance reports and penalties for poor performance.20 Have ready your fraud risk assessment, your written monitoring procedures with their last annual review, test results, and the signed vendor contract.

What it costs

Most vendors in this category do not publish prices, so expect a quote. NCUA warns that some credit unions signed steep termination penalties believing them fixed, when such terms are often negotiable.21 Have outside counsel read the exit terms before you sign.

Food for thought

The plaintiffs in Chen v. Bank of America had lost about $106,000 through remote access to an iPhone.22

Dilly Labs research, written from our catalog and cited sources · updated . Credit unions pay nothing. Vendors pay a referral fee only when a contract is signed through us. It never changes rankings or this guide. How we work

Sources

  1. RISK MANAGEMENT TOPICSwww.nacha.org
    ***NOTE: As June 19 is a federal holiday, the practical effective date for these two rules will be the next banking day – Monday, June 22, 2026.
  2. RISK MANAGEMENT TOPICSwww.nacha.org
    - The rule does not require pre-posting monitoring of credit entries.
  3. RISK MANAGEMENT TOPICSwww.nacha.org
    - **Phase 2 – June 19, 2026** - The rule will apply to all other RDFIs.
  4. Credit-Push Fraud Monitoring Resource Centerwww.nacha.org
    The Rules are neutral regarding specific methods or technologies used to identify fraudulently initiated credit transactions.
  5. Nacha fraud monitoring rules 2026: who must do what, by whenwww.botminds.ai
    October 1, 2024: false pretenses defined, R17 for suspected fraud codified, R06 for any reason, and the funds availability exemption.
  6. Nacha fraud monitoring rules 2026: who must do what, by whenwww.botminds.ai
    April 1, 2025: an RDFI must answer an ODFI's R06 request within ten banking days.
  7. Nacha Rule Changes: 1) Fraud Monitoring Phase 1 Effective Date: March 20, 2026georgiabanking.com
    The Company Entry Description field must contain “PAYROLL.”
  8. Nacha Rule Changes: 1) Fraud Monitoring Phase 1 Effective Date: March 20, 2026georgiabanking.com
    The Company Entry Description field must contain “PURCHASE.”
  9. New Nacha fraud rules to take effect in 2026www.americanbanker.com
    These procedures must be reviewed and updated at least annually to address constantly evolving fraud risks.
  10. TEN Credit Union selects digital banking platformatmmarketplace.com
    The agreement also includes options to activate Bankjoy's JoyCompass financial wellness tools and ... # TEN Credit Union selects digital banking plat...
  11. Lumin Digital Introduces Enhanced Identity Security Protection Solution from ID Dataweb - ID Datawebwww.iddataweb.com
    With biometric ... — October 15, 2024 — Leading cloud-native digital banking provider Lumin Digital (Lumin) today announced its partnership with ID D...
  12. Always-on fraud checks cut Suncoast's losses by a thirdwww.americanbanker.com
    ## From onboarding checks to constant vigilance Suncoast, which today holds $20.7 billion in assets and serves more than 1.3 million members, started ...
  13. Alkami and BioCatch strengthen digital banking fraud preventionfintech.global
    Raiz Federal Credit Union reported preventing more than $286,000 in fraud during its first year using BioCatch alongside other security measures.
  14. Michigan credit union blocks fraud with deepfake detectionwww.americanbanker.com
    East Landing-based Michigan State University Federal Credit Union partnered with the security tech company Pindrop, launching its Passport and Protect...
  15. NCUA’s Supervisory Priorities - A Look at What to Expect in 2026www.americascreditunions.org
    #### Fraud Prevention and Detection - Ensure strong monitoring and alerts to identify unusual and/or suspicious transaction activity.
  16. NCUA’s Supervisory Priorities - A Look at What to Expect in 2026www.americascreditunions.org
    - Conduct periodic updates and testing of fraud prevention processes and safeguards to keep them up to date and effective.
  17. 1 Authentication and Access to Financial Institution Services and Systemswww.ffiec.gov
    • Implementing layered security to protect against unauthorized access.
  18. 1 Authentication and Access to Financial Institution Services and Systemswww.ffiec.gov
    7 For purposes of this Guidance only, the term “customers” includes credit union members.
  19. 1 Authentication and Access to Financial Institution Services and Systemswww.ffiec.gov
    • Monitoring, logging, and reporting of activities to identify and track unauthorized access.
  20. ​Evaluating Third Party Relationshipsncua.gov
    - Typically, at a minimum, third party contracts should address the following: - Scope of arrangement, services offered, and activities authorized; - ...
  21. ​Evaluating Third Party Relationshipsncua.gov
    For example, some credit unions have entered into third party agreements with significant buyout or termination penalties, believing the penalties or ...
  22. The EFTA vs. Article 4A: Why Credit Unions Should Be Watching the Developing Litigation Over Fraudulent Wire Transfers - The Credit Union Connectionthecreditunionconnection.com
    The decision is particularly important because it adopts much of the reasoning advanced by the New York Attorney General in the Citibank litigation. ...
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