Writing a Rule: From Idea to Implementation

This course explores how changes to the Nacha Operating Rules begin, evolve, and ultimately move into practice. Students will examine where rule ideas originate, how needs are identified across the payments ecosystem, and why private-sector rulemaking plays a critical role in the ACH Network. The course walks through the lifecycle of a rule, including the Request for Comment and ballot process, while emphasizing the business case behind rule changes. Students will consider systemic impacts, opportunity costs, and implementation considerations, and will apply these concepts by developing and presenting a proposed rule along with a recommended implementation timeline.