Re: Request for Comment and Request for Information, Compliance and Operational Topics
|
|
- Blake Taylor
- 5 years ago
- Views:
Transcription
1 Stephen Kenneally Vice President Center for Regulatory Compliance Phone: October 24, 2014 Maribel Bondoc Manager, ACH Network Rules Sunrise Valley Drive Herndon, VA Re: Request for Comment and Request for Information, Compliance and Operational Topics Dear Ms. Bondoc: The American Bankers Association 1 (ABA) respectfully submits its comments to NACHA, The Electronic Payments Association, on the Request for Comment (RFC) and Request for Information (RFI) on Compliance and Operational Topics published on September 16, The RFI seeks input from the payments industry on five specific rule changes intended to improve the efficiency of the ACH Network. These proposed changes were identified by industry participants to increase the clarity of the rules or to lower operating costs. The RFI asks for feedback on possible methods to minimize the financial harm caused by corporate account takeover fraud that could be further refined in a future RFC. Proposed Rule Changes Recrediting Receiver-Removal of the Fifteen-Calendar-Day Notification Timeframe A long time ago, before the implementation of the Electronic Funds Transfer Act and Regulation E, NACHA rules required Receiving Depository Financial Institutions (RDFIs) to recredit a consumer Receiver for an unauthorized debit Entry promptly provided that the consumer notifies the RDFI within 15 days of the date that the RDFI sends or makes available information about the Entry to the Receiver. This portion of the NACHA rules would provide consumers less protection than available under Regulation E which requires a consumer be reimbursed for all unauthorized transactions when they are reported within 60 days of the periodic statement being made available to the consumer. In practice, Financial Institutions provide greater protections to consumers than required by the NACHA rules by complying with Regulation E. The proposed change to the NACHA rules would align the provision for prompt recredit with the RDFI s receipt of a Written Statement from the consumer and the RDFI s ability to transmit an extended return entry. The new rule would permit RDFIs to submit recredit return entries no later than 60 days following the settlement date of the original entry, the time period for which extended return entries are allowed. This change would provide more time for consumers to submit claims of unauthorized transactions and reduce confusion caused by the language referencing the unenforceable 15 day limit. 1 The American Bankers Association is the voice of the nation s $15 trillion banking industry, which is comprised of small, regional, and large banks that together employ more than 2 million people, safeguard $11 trillion in deposits and extend more than $8 trillion in loans. Learn more at
2 ABA supports this proposed rule change. Financial Institutions must comply with Regulation E and that requirement provides more consumer protection than the 15 day limit in the current NACHA rules. Eliminating the reference to the 15 day limit makes the rules clearer for all participants. The proposed effective date of September 18, 2015 is acceptable. TEL Entries Field Inclusion Requirement/Data Content for Payment Type Code Field This amendment would do two things. First, it would make the Payment Type Code field of a TEL entry required instead of optional. Second, it would eliminate the option to space-fill this field for Single Entry TEL entries, standardizing data content for all SEC Codes containing this field. TEL entries are reserved for ACH transactions initiated via telephone and WEB transactions are reserved for transactions initiated via the Internet. Currently, the Payment Type Code field is used to identify single or recurring transactions. TEL Entries permit a choice of S or spaces to identify a single entry and R for recurring transactions. This differs from WEB Entries that only permit the values of S or R. The rule change would make TEL entries subject to the same restrictions as WEB entries and increase the standardization of data across the network. ABA supports this proposed rule change. Standardizing TEL and Web entries will make it easier for ACH participants to standardize programming without having to make exceptions for Payment Type Code field differences. There will be costs associated with making this programming change, but they will be exceeded by the future benefits of standardization. The March 18, 2016 effective date is acceptable. Clarification of RDFI Warranties for Notifications of Change This rule change would make changes in the treatment of Notifications of Change. Notifications of Change are sent from RDFIs to ODFIs when Entries are received with incorrect data. The first change would clarify that an RDFI s warranty for information contained in a NOC would apply only to that information and removes language that suggests that the Receiver has authorized the underlying Entry. The RDFI only warrantees that the data is correct, not that the Receiver has granted authorization. For example, if an ODFI initiated a Debit Entry to a Receiver s account that included a misspelling of the Receiver s first name, the RDFI may issue a NOC with that correction. If it later is determined that the Debit Entry was not unauthorized, this rule change clarifies that the NOC sent by the RDFI correcting the name in no way validates that the Entry was approved by the Receiver. Second, an ODFI originating an Entry using data received via a NOC, would not be required to warranty that the adjusted data is correct. For example, an ODFI originates an Entry to a Receiver and the ODFI sends a NOC that includes a corrected account number. If the ODFI relies on the NOC s updated information, the ODFI would not be required to warranty that the updated data is correct. 2
3 ABA supports both proposed rule changes related to NOCs. The changes clarify that NOCs don t need to be validated by Receivers and that ODFIs won t be held liable for using information received in a NOC. It is appropriate to make clear that initiating NOCs is voluntary and that there is no obligation to match account names and account numbers to validate transactions. The effective date of September 18, 2015 is acceptable. Valid Characters for ACH Records This amendment is intended to clarify the characters that can be used within ACH Entries. In particular, NACHA has been receiving requests to provide information regarding the validity of using ASCII characters. This rule change would clarify that ASCII values, including extended ASCII characters may be used in ACH Entries. ABA supports this proposed rule. ABA recommends that NACHA consider creating a table of acceptable and unacceptable characters that can be used within ACH Entries. ABA recognizes that it can be difficult to keep such a database up to date, but believes that being able to determine with certainty which characters are eligible or not would be worth it. The effective date of March 18, 2015 is acceptable. Disclosure Requirements for POS Entries This rule change addresses circumstances where retailers have issued cards to consumers that use them to initiate Point of Sale (POS) Entries at those retailer locations. Retailers offer these products with customer loyalty programs and also use them to reduce credit card interchange costs. Financial Institutions have informed NACHA that these card products have caused confusion among consumers regarding overdraft protection and card network liability programs. The proposed rule would require Originators or Third-Party Service Providers that issue these ACH cards to provide specific disclosures to consumers prior to card activation. The three required disclosures would be: The ACH card is not issued by the consumer s Depository Financial Institution. POS Entries made with the ACH card that exceed the balance in the consumer s financial institution account may result in overdrafts and associated fees, regardless of whether the consumer has opted to allow overdrafts with respect to debit cards issued by the Depository Financial Institution that holds the account. Benefits and protections made using the ACH card may vary from those available through debit cards issued by the consumer s Depository Financial Institution. This proposal would not require these disclosures for any cards issued prior to the effective date. ABA supports this rule change because of the large number of customer service calls that its member banks must respond to that originate with retailer issued POS cards. Any effort that may cut down on the number and expense related to these inquiries needs to be explored. ABA 3
4 requests that additional details be provided on how this requirement will be monitored and enforced and which parties in the ACH Network will be held responsible for ensuring compliance with the disclosures. The September 18, 2014 effective date is acceptable. RFI-ODFI Request for Return for Fraudulently-Originated ACH Credit Entries NACHA is considering expanding the ODFI s Request for Return capability to provide Originators and ODFIs the means to attempt to recover funds lost due to unauthorized credit Entries commonly occurring during corporate account takeover frauds. Under current NACHA rules, when an Originator claims that a credit Entry was unauthorized, that Entry does not fall into the category of erroneous error that can be corrected easily. Reversing these payments requires the Receiver s authorization because the NACHA rules definition of erroneous entry is based on UCC 4A language that doesn t include fraudulentlyoriginated entries. Corporate account takeovers occur when a business authentication is compromised allowing the fraudster to gain control of their online banking system and create fraudulent credit entries. The NACHA RFI asks for input as to the concept of expanding the Erroneous Entry definition to include corporate account takeover scenarios where credits are initiated without authorization. NACHA outlines a situation where the ODFI could submit a Request for Return but the RDFI would not be obligated to honor it. If the RDFI agrees to make the return it would be indemnified against the loss by the ODFI. ABA applauds NACHA for recognizing the need to mitigate ODFI risks associated with corporate account takeover. ABA encourages NACHA to consider changes to network rules that could further this effort. ABA is supportive of the idea that ODFIs should be able to use the ODFI Request for Return process to recover fraudulently initiated ACH credit Entries. ABA also supports exploring a proposal where the ODFI could submit a Request for Return, but that would not compel the RDFI to accept that request. ABA is also supportive of further discussion where the ODFI would indemnify the RDFI from liability associated with the Request for Return. This would encourage RDFIs to accept the returns and place a substantial, but appropriate, responsibility on the ODFI for initiating the Return. The indemnification by the ODFI should also mitigate any RDFI concerns about Returns being initiated due to buyer s remorse and it should negate the need to require the ODFI produce proof or documentation. ABA appreciates the opportunity to comment on NACHA s Request for Comment and Request for Information on Compliance and Operational topics. We look forward to reviewing a more detailed proposal related to corporate account takeover mitigation in the near future. If you have any questions about these comments, please contact the undersigned at (202)
5 Sincerely, Stephen K. Kenneally Vice President 5
Re: Pain Points in the Rules, Request for Comment, August 17, 2010
Stephen Kenneally Vice President Center for Regulatory Compliance Phone: 202-663-5147 skenneal@aba.com By electronic delivery Mbondoc@nacha.org September 30, 2010 Maribel Bondoc Manager, Network Rules
More informationRe: Risk Management Enhancements, Request for Comment/Information, April 29, 2011
Stephen Kenneally Vice President Center for Regulatory Compliance Phone: 202-663-5147 skenneal@aba.com By electronic delivery Mbondoc@nacha.org June 24, 2011 Maribel Bondoc Manager, Network Rules NACHA,
More informationPain Points in the Rules Phase Two Request for Comment and Request for Information. Executive Summary and Rules Description June 27, 2011
Pain Points in the Rules Phase Two Request for Comment and Request for Information Executive Summary and Rules Description June 27, 2011 REQUEST FOR COMMENT RESPONSES DUE BY FRIDAY, AUGUST 19, 2011 NACHA
More informationNACHA Requests for Comment on ACH Quality and Risk Management Topics and ACH Rules Compliance Audit Requirements
Submitted via email July 20, 2018 Mr. Michael Herd Senior Vice President, ACH Network Administration NACHA The Electronic Payment Association 2550 Wasser Terrace, Suite 400 Herndon, VA 20171 Re: NACHA
More informationNACHA Rulemaking Process Update
NACHA Rulemaking Process Update NAFCU Webcast February 2, 2016 Amy Morris Senior Director, ACH Network Rules - NACHA 2 Agenda Standing Rules Work Group Activities Compliance and Operations Minor Rules
More informationAutomated Clearing House
Automated Clearing House THE SERVICE Customer wishes to initiate credit and/or debit Entries as an Originator through Bank to Accounts maintained at Bank and in other depository financial institutions
More informationFebruary 6, 2015 BY COURIER AND ELECTRONIC DELIVERY
February 6, 2015 BY COURIER AND ELECTRONIC DELIVERY Ms. Jan Estep, Chief Executive Officer NACHA 2550 Wasser Terrace, Suite 400 Herndon, VA 20171 Re: Same Day ACH Proposal Dear Ms. Estep: The Clearing
More information2015 NACHA COMPLIANCE SUMMARY GUIDE
2015 NACHA COMPLIANCE SUMMARY GUIDE Note: This compliance summary guide is provided by Jack Henry & Associates solely as a convenience to its ProfitStars Enterprise Payment Solutions customers and is not
More informationSession 8: ACH. New York Bankers Association-Community Bank Auditors Group Internal Audit Training-June 6-8, 2016
Session 8: ACH New York Bankers Association-Community Bank Auditors Group 2016 Internal Audit Training-June 6-8, 2016 MEMBER OF ALLINIAL GLOBAL, AN ASSOCIATION OF LEGALLY INDEPENDENT FIRMS 2016 Wolf &
More informationOld Point ACH Services Annual Training 2014
Old Point ACH Services Annual Training 2014 ACH Payments ACH Recipts ACH Collections ACH Payroll Introduction to ACH Services How does an ACH payment flow through the Network? Originator Originating Depository
More informationGet on First Base with Same-Day ACH Risks
Get on First Base with Same-Day ACH Risks EASTPAY 2016 Information Interchange Mary Gilmeister, AAP, NCP President WACHA Fred Laing, II, AAP, CCM, NCP President UMACHA 1 Disclaimer NACHA owns the copyright
More informationIs it an Unauthorized ACH Debit or Consumer Fraud? Biller Best Practices
Is it an Unauthorized ACH Debit or Consumer Fraud? Biller Best Practices Robert Unger, AAP, Senior Director Product Management and Corporate Relations, NACHA The Electronic Payments Association Frank D
More informationP2P, A2A Payments: Perils to Protection. WACHA Conference 2016 Kimberly W. Rector, AAP
P2P, A2A Payments: Perils to Protection WACHA Conference 2016 Kimberly W. Rector, AAP You Know the Drill The views and opinions expressed in this presentation are those of the presenter (and it is likely
More informationACH Management Policy
ACH Management Policy Original Issue Date: December 16, 2003 Last Revision Date: February 27, 2018 Last Review Date: February 27, 2018 Next Review Date: February 2019 Page 1 of 5 ACH Management Policy
More informationCORPORATE USER ACH QUICK REFERENCE CARD
What is the ACH Network? The Automated Clearing House (ACH) Network is the a network created for the electronic movement of money and other related data. This is a safe, secure, and reliable network for
More informationUCC 4A and the ACH Network. Presented by Wanda Downs, AAP Director of Payments Education
UCC 4A and the ACH Network Presented by Wanda Downs, AAP Director of Payments Education 2018 Audio Handouts Questions UCC 4A AND THE ACH NETWORK Wanda Downs, AAP Director of Payments Education Disclaimer
More informationTreasury Management Services Product Terms and Conditions Booklet
Treasury Management Services Product Booklet Thank you for choosing M&T Bank for your treasury management service needs. We appreciate the opportunity to serve you. If you have any questions about this
More informationORIGINATING ACH ENTRIES REFERENCE
ORIGINATING ACH ENTRIES REFERENCE The following information has been provided so that customers can be familiar with their requirements under the NACHA Operating Rules (The Rules). This quick reference
More informationTreasury Management Services Product Terms and Conditions Booklet
Treasury Management Services Product Booklet Thank you for choosing M&T Bank for your treasury management service needs. We appreciate the opportunity to serve you. If you have any questions about this
More informationFinancial Management Service Docket FISCAL-FMS , Management of Federal Agency Disbursements; 75 Federal Register, ; June 17, 2010
Stephen Kenneally Vice President Center for Regulatory Compliance Phone: 202-663-5147 skenneal@aba.com August 16, 2010 By electronic delivery to: Mr. Walt Henderson Financial Management Service 401 14
More informationKey Components of an RDFI. Mini Deck
Key Components of an RDFI Mini Deck Disclosure 2017 PaymentsFirst. All rights reserved. This material is not intended to provide any warranties or legal advice, and is intended for educational purposes
More information5/2/2017. Mini Deck. Disclosure
Key Components of an RDFI Mini Deck Disclosure 2017 PaymentsFirst. All rights reserved. This material is not intended to provide any warranties or legal advice, and is intended for educational purposes
More informationBusiness to Business Payments
presents Business to Business Payments The CCD and CTX Entry Disclaimer 2011 NEACH. All rights reserved. This material is not intended to provide any warranties or legal advice, and is intended for educational
More informationIAT Modifications Request for Comment. Executive Summary and Rules Description August 15, 2012
IAT Modifications - 2012 Request for Comment Executive Summary and Rules Description REQUEST FOR COMMENT RESPONSES DUE BY MONDAY, SEPTEMBER 24, 2012 NACHA requests comment on three proposed amendments
More informationService Agreement. UltraBranch Business Edition. alaskausa.org AKUSA R 05/15
Service Agreement UltraBranch Business Edition Your savings federally insured to at least $250,000 and backed by the full faith and credit of the United States Government. National Credit Union Administration,
More informationACH Primer for Healthcare. A Guide to Understanding EFT Payments Processing
ACH Primer for Healthcare A Guide to Understanding EFT Payments Processing ACH Primer for Healthcare A Guide to Understanding EFT Payments Processing 2011 NACHA The Electronic Payments Association All
More informationTreasury Management Services Product Terms and Conditions Booklet
Treasury Management Services Product Booklet Thank you for choosing M&T Bank for your treasury management service needs. We appreciate the opportunity to serve you. If you have any questions about this
More informationWire Transfer & ACH Origination. What will you learn? Wire Transfer Origination. After this course, you will be able to:
Wire Transfer & ACH Origination Regional Payments Associations, through their Direct Membership in NACHA, are specially recognized and licensed providers of ACH education, publications and support. Regional
More informationPayments Fraud Liability Matrix
s Fraud Liability Matrix s Fraud Liability Matrix Prepared by the Federal Reserve Bank of Minneapolis s, Standards, and Outreach Group April 2018 2018 Federal Reserve Bank of Minneapolis, not to be used
More informationPerformed by: The Payments Authority, under the oversight of AuditLink. October 22, 2013
Performed by: The Payments Authority, under the oversight of AuditLink October 22, 2013 October 21, 2013 On September 9, 2013 the Payments Authority conducted the CU*Answers annual ACH Audit. The overall
More informationCommercial Banking Online Service Agreement
Effective November 1, 2017 Commercial Banking Online Service Agreement Download PDF Welcome to Commercial Banking Online at Washington Federal. This Commercial Banking Online Service Agreement ( Agreement
More informationEXTERNAL FUNDS TRANSFER DISCLOSURE
In this Disclosure and Agreement, the words "you" and "your" mean the member or Joint Owners that applied for and/or uses any of the External Linked/Accounts Funds Transfer Services (the "Services") described
More informationCopyright 2017 Lakeland Bank. All rights reserved. This material is proprietary to and published by Lakeland Bank for the sole benefit of its
ACH Originator Guide Copyright 2017 Lakeland Bank. All rights reserved. This material is proprietary to and published by Lakeland Bank for the sole benefit of its clients. Reproduction, distribution, disclosure
More informationCASH MANAGEMENT SCHEDULE. AUTOMATED CLEARING HOUSE SERVICES for Originators & Third-Party Senders
CASH MANAGEMENT SCHEDULE AUTOMATED CLEARING HOUSE SERVICES for Originators & Third-Party Senders This Schedule is entered into by and between Santander Bank, N.A. ( Bank ) and Customer identified in the
More informationUNDERSTANDING ACH First Tennessee Bank National Association. Member FDIC.
UNDERSTANDING ACH 2015 First Tennessee Bank National Association. Member FDIC. www.firsttennessee.com OVERVIEW The National Automated Clearing House Association (NACHA) regulates the use of the ACH system.
More informationThe ACH Network: Progress and Pathways to Faster Payments
The ACH Network: Progress and Pathways to Faster Payments 2017 Merchant Acquirer s Committee Annual Conference March 21, 2015 Las Vegas, NV 2 Agenda NACHA ACH Network Recent and Upcoming Rules Changes
More informationFunds Transfer Services
Funds Transfer Services Understanding the Terms and Conditions of your Account as well as the Federal laws and regulations that outline your rights and responsibilities as a Consumer and Non-Consumer (Commercial
More informationONLINE BANKING DISCLOSURE STATEMENT AND AGREEMENT
ONLINE BANKING DISCLOSURE STATEMENT AND AGREEMENT Welcome to BankUnited. This Online Banking Disclosure Statement and Agreement (this Agreement ), together with the Application, Enrollment and Set-Up Form
More informationRetail Payments Office of the Federal Reserve System 1000 Peachtree Street, N.E. Atlanta, GA
Retail Payments Office of the Federal Reserve System 1000 Peachtree Street, N.E. Atlanta, GA 30309-4470 Dear CEO: As an ACH operator, our highest priority is making the ACH system as safe and secure as
More informationACH FUNDAMENTALS: UNDER THE MICROSCOPE. Heather Spencer, AAP Implementation Coordinator, MY CU Services, LLC. Disclaimer
ACH FUNDAMENTALS: UNDER THE MICROSCOPE Heather Spencer, AAP Implementation Coordinator, MY CU Services, LLC www.mycuservices.com Disclaimer This material is not intended to provide any warranties or legal
More informationFARMERS INSURANCE FEDERAL CREDIT UNION
FARMERS INSURANCE FEDERAL CREDIT UNION ELECTRONIC SERVICES DISCLOSURE AND AGREEMENT In this Disclosure and Agreement, the words I, me, mine, my, us, and our mean each and all of those (whether one or more
More informationTREASURY MANAGEMENT MASTER AGREEMENT TERMS AND CONDITIONS
TREASURY MANAGEMENT MASTER AGREEMENT TERMS AND CONDITIONS PLEASE NOTE THAT THESE TERMS AND CONDITIONS ARE A PART OF THE TREASURY MANAGEMENT MASTER AGREEMENT WHICH YOU HAVE READ AND SIGNED. ALL TERMS AND
More informationRisks with Same-Day ACH. Presented by Kevin Olsen, AAP NCP Senior Vice President, Payments Education
Risks with Same-Day ACH Presented by Kevin Olsen, AAP NCP Senior Vice President, Payments Education 2017 Audio Handouts Questions RISKS WITH SAME DAY ACH Kevin Olsen, AAP, NCP SVP of Payments Education
More informationGlossary of ACH Terms
ABA NUMBER See Routing Number/Transit ACH - The Automated Clearing House network ACCESS DEVICE - A card, code, or other means of access to a consumer s account that may be used to initiate electronic funds
More informationExpanding Same Day ACH
Expanding Same Day ACH NACHA Request for Comment December 1, 2017 2 Expanding Same Day ACH - Introduction NACHA invites comments on proposed rules to expand Same Day ACH. Currently, Same Day ACH is available
More informationACH Credit a transaction through the ACH network originated to pay a receiver (deposit funds into an account).
ACH Glossary For additional information, refer to the current National Automated Clearing House Association (NACHA) Rules or contact us at 205-469-4000 or 888-902-4227. ABA Number also known as Routing/Transit
More informationACH Origination Agreement (Company) has requested that Easthampton Savings Bank (bankesb) permit it to initiate Entries to Accounts maintained at the
ACH Origination Agreement (Company) has requested that Easthampton Savings Bank (bankesb) permit it to initiate Entries to Accounts maintained at the bank and other Financial Institutions by means of the
More informationRISKS WITH SAME DAY ACH
RISKS WITH SAME DAY ACH Kevin Olsen, AAP, NCP SVP of Payments Education About epayresources Not-for-profit Regional Payments Association Educational Programs & Payments Publications Member Benefits Voice
More informationCheck 21 FAQ. Frequently Asked Questions
Check 21 FAQ Frequently Asked Questions Below is a list of frequently asked questions based upon: Check Clearing for the 21st Century Act Signed by President Bush on October 28, 2003 Regulation CC (12
More informationAUTOMATED CLEARING HOUSE (ACH) THIRD PARTY SERVICE PROVIDER ADDENDUM TO THE BUSINESS ONLINE USER AND ACCESS AGREEMENT
AUTOMATED CLEARING HOUSE (ACH) THIRD PARTY SERVICE PROVIDER ADDENDUM TO THE BUSINESS ONLINE USER AND ACCESS AGREEMENT We suggest you read this document carefully and print a copy for your reference. You
More informationKey Learning Points. Disclaimer. Compliance and Payments: A View of the Legal Framework. Lori Moore, CRCM ATTUS Technologies, Inc.
Compliance and Payments: A View of the Legal Framework Lori Moore, CRCM ATTUS Technologies, Inc. Key Learning Points Identify existing rules and regulations applicable to various payment methods Understanding
More informationAuthorizations & Agreements. Presented by Laura Nelson, AAP NCP Education Specialist/Auditor
Authorizations & Agreements Presented by Laura Nelson, AAP NCP Education Specialist/Auditor Audio Handouts Questions Presented by: PAR/WACHA - The Premier Payments Resource Laura Nelson, AAP, NCP Education
More informationThis is designed to provide those who are not familiar with the ACH Network with a basic understanding of the fundamentals of the ACH Network.
This is designed to provide those who are not familiar with the ACH Network with a basic understanding of the fundamentals of the ACH Network. The ACH Network is a batch processing, store and forward system.
More informationEnhancements to ACH Applications ARC, BOC, POP, TEL and XCK; Collection of Service Fees Request for Comment
Enhancements to ACH Applications ARC, BOC, POP, TEL and XCK; Collection of Service Fees Request for Comment Executive Summary and Rules Description June 24, 2010 REQUEST FOR COMMENT RESPONSES DUE BY FRIDAY,
More informationMarch 1, NACHA OPERATING RULES AND GUIDELINES ERRATA #1
2012 NACHA OPERATING RULES AND GUIDELINES ERRATA #1 NACHA Operating Rules Following are two corrections to the 2012 NACHA Operating Rules. Please be sure to note these changes in your copy of the 2012
More informationOBLIGATIONS OF ORIGINATORS
OBLIGATIONS OF ORIGINATORS Revised September 2017 Legal Framework for ACH ACH Operating Rules- NACHA A series of contract law that is made binding by agreements. Regulation E Carries out the purpose of
More informationUCC (Uniform Commercial Code) Article 4A. Mini Deck
UCC (Uniform Commercial Code) Article 4A Mini Deck Disclosure 2017 PaymentsFirst. All rights reserved. This material is not intended to provide any warranties or legal advice, and is intended for educational
More informationUCC (Uniform Commercial Code) Article 4A
UCC (Uniform Commercial Code) Article 4A Mini Deck Disclosure 2017 PaymentsFirst. All rights reserved. This material is not intended to provide any warranties or legal advice, and is intended for educational
More informationNEACH Payments Management Conference ACH Credit Risk: Credits, Debits, Same Day
ACH Credit Risk: The Credits, The Debits and The Same Day ACH Effect Jennifer Wasmund, AAP, NCP, Vice President of Education and Compliance, UMACHA www.neach.org 2016 NEACH. All rights reserved. Jen Wasmund,
More informationACH Originator Resources
ACH Originator Resources Revised 06-2017 Table of Contents Introduction...3 ACH Originator Responsibilities...4 ACH Glossary...5 Notification of Change (NOC) Codes... Error! Bookmark not defined. ACH Return
More informationAuthorization Approval of a transaction by the financial institution that issued a paycard or other payment card.
APA Visa Paycard Portal Glossary of Terms Account Number A unique number assigned by a financial institution to a customer s account. The account number for a paycard is embossed or imprinted on the card
More informationSame Day ACH: Preparing for Debits. Presented by Laura Nelson, AAP NCP Education Specialist/Auditor
Same Day ACH: Preparing for Debits Presented by Laura Nelson, AAP NCP Education Specialist/Auditor Audio Handouts Questions Presented by: PAR/WACHA-The Premier Payments Resource Laura Nelson, AAP, NCP
More informationNOTICE OF AMENDMENT TO THE 2016 NACHA OPERATING RULES SUPPLEMENT #1-2016
NOTICE OF AMENDMENT TO THE 2016 NACHA OPERATING RULES February 17, 2016 SUPPLEMENT #1-2016 Establishment of the Unauthorized Entry Fee Effective Date: October 3, 2016 2016 NACHA The Electronic Payments
More information(For sweep accounts.) Total dividends earned as of the last day of the statement period. (For line of credit.) Amount advanced today.
Contents: Glossary A B C D E F G H I J K L M N O P Q R S T U V W X Y Z A Top Account Reconciliation Plan (ARP) Accrued Dividends Month to Date ACH Addenda Advance Today Automated Clearing House (ACH) ARP
More informationACH Origination Agreement
ACH Origination Agreement Company Information Company Name Address City, State, Zip hereafter referred to as Company. This Agreement is made on this day of, 2 0, by and between Company and Lakeland Bank
More information2016 Annual ACH Audit CU*Answers
2016 Annual ACH Audit CU*Answers September 6, 2016 Marsha Sapino, AAP, BSACS AuditLink Assistant Manager 6000 28 th St SE Grand Rapids, MI 800-327-3478 ext.380 Marsha.sapino@cuanswers.com Jim Vilker, NCCO
More informationDocket No. CFPB Mortgage Servicing Rules Under the Real Estate Settlement Procedures Act (Regulation X)
Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 By electronic delivery to: www.regulations.gov Re: Docket No. CFPB-2017-0031
More informationREGULATION GG YOUR NEW OBLIGATIONS TO STOP UNLAWFUL INTERNET GAMBLING
REGULATION GG YOUR NEW OBLIGATIONS TO STOP UNLAWFUL INTERNET GAMBLING BY AMY AVITABLE ASSOCIATE DIRECTOR METAVANTE REGULATORY SERVICES SPRING 2009 Agenda Overview of requirements What is unlawful internet
More informationFees There are currently no separate monthly or transaction fees assessed by the Bank for use of the Online Banking Service including the External
Online Banking Account Agreement General This Online Banking Agreement (Agreement) for accessing your TrustTexas Bank, SSB account(s) via the Internet explains the terms and conditions of Online Banking.
More informationNavigating the ACH Rules
Navigating the 2018 ACH Rules This material is not intended to provide any warranties or legal advice, and is intended for education purposes only. NACHA owns the copyright for the NACHA Operating Rules
More informationDecember 3, ACH Rulebook Subscribers. Cari Conahan, AAP Senior Director, Network Rules
December 3, 2010 TO: FROM: ACH Rulebook Subscribers Cari Conahan, AAP Senior Director, Network Rules RE: 2010 NACHA Operating Rules ᅳ Supplement #2-2010 Application Enhancements FOR YOUR INFORMATION: On
More informationACH Industry Update, Audit Weaknesses and Emerging Payment Trends
ACH Industry Update, Audit Weaknesses and Emerging Payment Trends Presented by Adrian Brown, AAP Director of Education The Payments Authority is the association for payments people. ACH CARD CHECK WIRE
More informationApril 3, By electronic delivery to:
Nessa Feddis Senior Vice President & Deputy Chief Counsel for Consumer Protection and Payments Center for Regulatory Compliance Government Relations Regulatory & Trust Affairs 202 663 5433 nfeddis@aba.com
More informationRabo Commercial Banking (RCB) Agreement
Rabo Commercial Banking (RCB) Agreement Acceptance of this Agreement You accept the terms and conditions of this Agreement, as well as any amendments that may be made to this Agreement from time to time,
More informationSame Day ACH: What Does It Mean to Your Financial Institution?
Same Day ACH: What Does It Mean to Your Financial Institution? Presented by WACHA Pre- Conference PAR/WACHA-The Premier Payments Resource Panelists: Laura Parsons FIS Wendy Stanford Bankers Bank Stacy
More informationBeneficial State Bank ONLINE BANKING ACCESS AGREEMENT AND ELECTRONIC FUNDS TRANSFER ACT DISCLOSURE
Beneficial State Bank Services and Prices Effective 2-1-2018 ONLINE BANKING ACCESS AGREEMENT AND ELECTRONIC FUNDS TRANSFER ACT DISCLOSURE Agreement This Agreement is a contract which establishes the rules
More informationKelly Community Federal Credit Union External Account Funds Transfer Disclosure
External Account Funds Transfer Agreement This External Account Funds Transfer Agreement sets forth the terms and conditions under which Kelly Community Federal Credit Union (Us, We, Our, the Credit Union)
More informationImproving ACH Network Quality by Reducing Exceptions Request for Comment and Information
Improving ACH Network Quality by Reducing Exceptions Request for Comment and Information Executive Summary and Rules Description November 11, 2013 RESPONSES DUE BY MONDAY, JANUARY 13, 2014 NACHA requests
More informationZions Bank PC Banking Enrollment Form
Zions Bank PC Banking Enrollment Form To enroll in ZB, N.A. dba Zions Bank PC Banking, please complete this form and return it in one of the following ways: the nearest Zions Bank Financial Center, email
More information21 Billion ACH Transactions: Yep, Something s Going to Go Wrong!!! WACHA Conference 2014 Kimberly W. Rector, AAP MACHA
21 Billion ACH Transactions: Yep, Something s Going to Go Wrong!!! WACHA Conference 2014 Kimberly W. Rector, AAP MACHA My Sideways Mind!!!! 1983 = 69% of 17 year olds had drivers licenses 2008 = 50% of
More informationCustomer Access Agreement
First National Bank of Kemp 100 South State Highway 274 PO BOX 587 Kemp, TX 75143 (903) 498-8541 https://www.fnbkemp.com Customer Access Agreement You agree that any information or disclosures or notices
More informationNACHA Operating Rules: What Do They Mean to You?
NACHA Operating Rules: What Do They Mean to You? 2015 NACHA The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA.
More informationMerchant Services Application and Agreement
Merchant Services Application and Agreement PLEASE REMIT APPLICATION TO: (OVERNIGHT DELIVERY RECOMMENDED) BE SURE TO INCLUDE TH E FOLLOWING MATERIALS: VOIDED CHECK FROM SETTLEMENT ACCOUNT BUSINESS FORMATION
More informationAugust 14, By electronic delivery to:
Nessa Feddis Senior Vice President & Deputy Chief Counsel for Consumer Protection and Payments Center for Regulatory Compliance Government Relations Regulatory & Trust Affairs 202 663 5433 nfeddis@aba.com
More informationSame Day ACH Transaction Risk
Same Day ACH Transaction Risk The Clearing House Puerto Rico Payment Symposium August 21, 2015 Same Day Risk Agenda: Same Day ACH Background Settlement Operations Returns Risk Associated with Same Day
More informationIMPORTANT ACCOUNT INFORMATION FOR OUR CUSTOMERS from. The Tri-County Bank 106 N Main St Stuart, NE (402)
IMPORTANT ACCOUNT INFORMATION FOR OUR CUSTOMERS from The Tri-County Bank 106 N Main St Stuart, NE 68780 (402)924-3861 ELECTRONIC FUND TRANSFERS YOUR RIGHTS AND RESPONSIBILITIES Indicated below are types
More informationNew ACH Stop Payment and Written Statement of Unauthorized Debit Requirements
New ACH Stop Payment and Written Statement of Unauthorized Debit Requirements Patty Presta, AAP Michael Gilchrist, AAP 2008 Western Payments Alliance. All rights reserved. No reproduction or distribution
More informationAgenda. New ACH Stop Payment and Written Statement of Unauthorized Debit Requirements. ACH Stop Payment Requirements Regulation E
2008 Western Payments Alliance. All rights reserved. No reproduction or distribution in any manner without prior written consent. New ACH Stop Payment and Written Statement of Unauthorized Debit Requirements
More informationUNFCU Digital Banking Agreement
UNFCU Digital Banking Agreement Please read this Digital Banking Agreement (the Agreement ) carefully. This Agreement sets forth the terms and conditions that govern your use of UNFCU s Digital Banking
More informationADDENDUM TO ONLINE BANK AGREEMENT FOR CASH MANAGEMENT SERVICES- AUTOMATED CLEARING HOUSE ODFI ORIGINATOR AGREEMENT (S-1)
ADDENDUM TO ONLINE BANK AGREEMENT FOR CASH MANAGEMENT SERVICES- AUTOMATED CLEARING HOUSE ODFI ORIGINATOR AGREEMENT (S-1) THIS AGREEMENT is made this day of,, by and between (the "Customer") and Israel
More informationACH Risk: Is It a Myth or Reality. Mary Gilmeister, AAP, NCP President WACHA Fred Laing, II, AAP, CCM, NCP President UMACHA
ACH Risk: Is It a Myth or Reality Mary Gilmeister, AAP, NCP President WACHA Fred Laing, II, AAP, CCM, NCP President UMACHA Disclaimer WACHA and UMACHA, through their Direct Membership in NACHA, are specially
More informationCal Coast Online Terms and Conditions Agreement
Cal Coast Online Terms and Conditions Agreement California Coast Credit Union maintains Cal Coast Online as a service to our members. This Terms and Conditions Agreement ( Agreement ) governs your use
More informationecorp Online Banking Access Agreement
ecorp Online Banking Access Agreement This Corporate Internet Banking Service Agreement ( Agreement ) is a contract which establishes the rules which cover your electronic access to your accounts at the
More informationADDENDUM F COMBINED COMERICA WEB PAY EXPRESS AND COMERICA WEB INVOICING TERMS AND CONDITIONS
Effective 01/24/2016 ADDENDUM F COMBINED COMERICA WEB PAY EXPRESS AND COMERICA WEB INVOICING TERMS AND CONDITIONS This Addendum F is incorporated by this reference into the Comerica Web Banking Terms and
More informationPersonal Electronic External Transfers Agreement
Effective Date: January 2016 GENERAL The terms you and your refer to the individual customer accepting this Personal Electronic Transfer Agreement (this Agreement ). The terms our, we, and us refer to
More informationDIRECT CONNECT SERVICE AGREEMENT with optional bill payment service (ver. November 2017)
DIRECT CONNECT SERVICE AGREEMENT with optional bill payment service (ver. November 2017) This Direct Connect Service Agreement ( Agreement ) governs the Direct Connect Service (the Service ) provided by
More informationTreasury Management Services Terms and Conditions
Treasury Management Services Terms and Conditions I. INTRODUCTION This Treasury Management Services Terms and Conditions ( Terms and Conditions ) governs the use of all treasury management services ( Services
More informationKEYBANK BUSINESS ONLINE PAY WITH ACH SERVICE
KEYBANK BUSINESS ONLINE PAY WITH ACH SERVICE Terms and Conditions As used in these terms and conditions (herein called Terms and Conditions ) for the Bank s Pay with ACH online electronic funds transfer
More informationTreasury Management Services Agreement
Treasury Management Services Agreement AUTHORIZATION AND AGREEMENT FOR TREASURY MANAGEMENT SERVICES The Undersigned hereby request and authorize this Treasury Management Services Agreement ( Agreement
More informationPresented by: Jen Wasmund, AAP, NCP Vice President of Education and Compliance. Jordan Morell, AAP, NCP Associate Director of Education Services
Presented by: Jen Wasmund, AAP, NCP Vice President of Education and Compliance Jordan Morell, AAP, NCP Associate Director of Education Services Regional Payments Associations, through their Direct Membership
More information