Consumer Banking and Payments Law: 5.17.5 Private Enforceability of NACHA Rule Violations
NACHA rules apply to virtually all ACH entries transmitted through an ACH operator.1573 But they are not a public body of law, and they do not create a right of action for consumers.
Many of the rules do create rights for consumers (such as the right to stop payment, revoke authorization, or receive re-credit for an unauthorized transfer). Because a consumer is an obvious beneficiary of the rules, one might reasonably assume that a consumer may bring a third-party beneficiary contract claim to enforce compliance with the rules.