Compliance Prompt for Nacha Phase 2 ACH Account Ownership Monitoring

Luna, cross-examine our outbound non-consumer ACH origination files against the updated Nacha Phase 2 risk-management and account-validation criteria. Build continuous-monitoring alerts that trace anomalies in account descriptors or routing coordinates before each batch is permanently transmitted to the network.

INPUT, the user will paste:
- Outbound non-consumer origination file inventory (SEC codes such as CCD and CTX, entry counts, settlement and transmission cutoff windows)
- Per-entry detail (receiver name, routing number, account descriptor, amount, payee enrollment date)
- Current account-validation method and the re-validation triggers (new payee, amount change, dormant receiver)
- Existing descriptor and routing-anomaly rule set
- Prior return, reversal, and fraud history by receiver

OUTPUT, return the following structured response:

1. NACHA CRITERIA GAP MAP
For each Nacha Phase 2 risk-management and account-validation criterion:
- The criterion and the rule reference
- Current firm-level coverage (covered, partial, gap)
- Specific evidence of coverage or the evidence-absence reason

2. BATCH ANOMALY MAP
For each flagged origination entry:
- Entry ID, receiver, and amount
- The descriptor or routing signal that fired (transposed or substituted routing digits, blank or inconsistent descriptor, penny-test pattern, new-payee velocity)
- Fraud-likelihood band and the dominant signal that drove it
- Hold-or-release recommendation against the transmission cutoff

3. ACCOUNT-VALIDATION COVERAGE LAYOUT
- Validation method in force at each origination touchpoint (enrollment, amount change, new payee, dormant-receiver reactivation), by SEC code
- Re-validation cadence and the gaps where an entry transmits without a fresh ownership check
- The validation upgrade recommended per gap

4. CONTINUOUS-MONITORING ALERT RULES
For each alert to deploy:
- The rule logic, the threshold, and the SEC codes it covers
- Whether it holds the single entry or the full batch, and the owning agent
- Expected catch rate and the projected false-positive impact on clean batches

5. SAR AND AUDIT EVIDENCE BUNDLE
- The records to retain at flag time for a downstream SAR filing (entry, rule fired, decision rationale, time-to-disposition)
- Cryptographic receipts binding each held event to a specific batch, entry, and rule
- How holds and dispositions route from Luna to the payment-operations and BSA owners

Be specific. Quote entry IDs and routing or descriptor signals where the analysis surfaces an anomaly, and cite the Nacha rule reference where you can. Where input is insufficient to assess a criterion or an entry, flag the question instead of guessing.