Learning objectives
- Execute the NACHA Operating Rules §2.5 reversal window inside the 5-banking-day clock.
- Decide on customer-facing notification under conflicting Reg E and BSA confidentiality constraints.
- Coordinate the FinCEN SAR filing decision against the 30-day initial deadline.
- Produce a documented IR exercise artifact mapped to FFIEC CAT and NYDFS §500.17.
Scenario brief
## Scenario context Second financial-institutions anchor scenario. While the wire-fraud scenario covers the inbound BEC/wire pattern, this scenario sits on the origination side of the ACH rails — the harder and rarer exercise. Built for community banks, credit unions, and FinTechs that act as ODFIs (originating depository financial institutions) and need documented evidence of a tested payments-fraud response for FFIEC, NCUA, NYDFS, and external auditor review. ## Sample inject sequence 1. **T+00:00** — Operations spots an anomalous batch totaling $1.4M across 47 credits to first-time receivers at the same downstream RDFI. 2. **T+00:35** — RDFI calls back: 31 of 47 receivers are flagged pass-through accounts; funds already swept. 3. **T+01:10** — Counsel asks whether the SAR clock starts at detection or at confirmation. BSA officer wants both answers in writing. 4. **T+02:00** — Customer (the legitimate originator) demands a public statement; PR is on the line. > Full inject set unlocks in the live product. The marketing demo runs the > first three injects only.