Payment System Rules and Regulations. What will you learn? After this course, you will be able to:

Similar documents
International ACH Transaction (IAT) Exception Handling. Presented by Laura Nelson, AAP, NCP Auditor/Education Specialist

ACH FUNDAMENTALS: UNDER THE MICROSCOPE. Heather Spencer, AAP Implementation Coordinator, MY CU Services, LLC. Disclaimer

UCC 4A and the ACH Network. Presented by Wanda Downs, AAP Director of Payments Education

Bank Secrecy Act and OFAC Compliance Board of Directors Training

Key Components of an RDFI. Mini Deck

5/2/2017. Mini Deck. Disclosure

REGULATION GG YOUR NEW OBLIGATIONS TO STOP UNLAWFUL INTERNET GAMBLING

Wire Transfer & ACH Origination. What will you learn? Wire Transfer Origination. After this course, you will be able to:

ACH Management Policy

Key Learning Points. Disclaimer. Compliance and Payments: A View of the Legal Framework. Lori Moore, CRCM ATTUS Technologies, Inc.

Anti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide

ACH Industry Update, Audit Weaknesses and Emerging Payment Trends

UMACHA 2014; All rights reserved 2

Service Agreement. UltraBranch Business Edition. alaskausa.org AKUSA R 05/15

Commercial Banking Online Service Agreement

BSA/AML & OFAC Volunteer Compliance Training. Agenda

Authorizations & Agreements. Presented by Laura Nelson, AAP NCP Education Specialist/Auditor

Funds Transfer Services

Anti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide

Bank Secrecy Act- USA Patriot Act Compliance

IAT Modifications Request for Comment. Executive Summary and Rules Description August 15, 2012

Account Disclosures. RDFI should review and update account disclosures to address:

EXTERNAL FUNDS TRANSFER DISCLOSURE

Definitions AML/BSA Risks Assess Your Risks Identify the Risks Mitigate the Risks Scenario Questions?

Trans-Fast Remittance LLC. AML Compliance Training for Agents

Copyright 2017 Lakeland Bank. All rights reserved. This material is proprietary to and published by Lakeland Bank for the sole benefit of its

Same Day ACH: What Does It Mean to Your Financial Institution?

BSA/AML Hot Topics and UIGEA Daniel Hastings Financial Institution Examiner - FDIC

Developments in Anti-Money Laundering Regulation for Investment Advisers and Funding Portals. May 2016

ANTI-MONEY LAUNDERING COMPLIANCE GUIDE

Bank Secrecy Act for Directors

UCC (Uniform Commercial Code) Article 4A. Mini Deck

UCC (Uniform Commercial Code) Article 4A

OFAC Compliance Officer Responsibilities. OFAC Regulations. Transactions Subject to OFAC. Reviewed by and Date:

AGENT ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM FOR MONEY ORDER SALES

for Boards 2015 Spring Leadership Development Conference

ACH Risk: Is It a Myth or Reality. Mary Gilmeister, AAP, NCP President WACHA Fred Laing, II, AAP, CCM, NCP President UMACHA

Same Day ACH: Moving Payments Faster

OBLIGATIONS OF ORIGINATORS

Business to Business Payments

DISCLOSURE FOR ELECTRONIC FUND TRANSACTIONS (EFT) AND WIRE TRANSFER NOTIFICATION

2016 Annual ACH Audit CU*Answers

Important Compliance Dates December 2017

Bank Secrecy Act Examination Procedures. Sections 313, 314, and 319(b) of the USA PATRIOT Act (31 CFR , , , 103.

CASH MANAGEMENT SCHEDULE. AUTOMATED CLEARING HOUSE SERVICES for Originators & Third-Party Senders

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.

AUTO-OWNERS ASSOCIATES CREDIT UNION POLICY AND PROCEDURES MANUAL

UNDERSTANDING YOUR BUSINESS ACCOUNTS

Automated Clearing House

Federal Reserve Bank of Dallas

PRESIDENTIAL LIFE INSURANCE COMPANY

Get on First Base with Same-Day ACH Risks

8300/OFAC COMPLIANCE. Aka: What you don t know can hurt you. Presented by: Robert Frimet, CAMS

ACH Credit a transaction through the ACH network originated to pay a receiver (deposit funds into an account).

ACH Audit and Risk Assessment: Choose Your Own Adventure

Glossary of ACH Terms

2015 NACHA COMPLIANCE SUMMARY GUIDE

Managing Third Party Risk in the ACH Network

Bank Secrecy Act. The board establishes adequate policies and procedures in accordance with anti-money laundering laws and regulations.

Terms and Conditions for Certificate of Deposit Accounts

Example of Credit Card Agreement for Bank of America Visa Signature accounts

Directory of ACH Return Codes

ANTI-MONEY LAUNDERING COUNTRY GUIDE: UNITED STATES OF AMERICA

Compliance with the Joint Rule on Unlawful Internet Gambling Enforcement Act--What Now? June 10, 2010

ALLY BANK ONLINE BANKING SERVICES AGREEMENT. Version 14.0, November 4, 2017

How Could the Changes in Regulation CC Affect You? Angie Smith, AAP, NCP VP, Professional Development Events April 24, 2014

Golden 1 Visa Credit Card Agreement

This information is accurate as of March 31, 2017.

Bank Secrecy Act for Operations Staff

1120 Connecticut Avenue, NW Washington, DC BANKERS John J. Byrne

DEPOSIT ACCOUNT AGREEMENT AND DISCLOSURE

Pain Points in the Rules Phase Two Request for Comment and Request for Information. Executive Summary and Rules Description June 27, 2011

Navigating the ACH Rules

ORIGINATING ACH ENTRIES REFERENCE

TokenLot, LLC BSA Officer TokenLot, LLC Board of Directors

NACHA Operating Rules Update: Healthcare Payments

Terms and Conditions for Checking and Savings Accounts

2016 BSA/AML/OFAC Training Series

Inactive Account Fees Any account inactive for one year, with a balance under $50.00, will be assessed a $2.00 charge per month.

ARE YOU READY FOR SAME DAY ACH??

Consumer Electronic Fund Transfer Agreement and Disclosure

Mobile Deposit Capture Agreement and Disclosure Mobile Deposit Capture ("Mobile Deposit") Georgia s Own Credit Union ( Georgia s Own )

Business Deposit Account Agreement

Jamie L. Howell, CUCE

Representment Terms & Conditions

New Cumberland Federal Credit Union NCFCU Remote Xpress Deposit Terms and Conditions Agreement

Business Merchant Capture Agreement. A. General Terms and Conditions

ACH Origination Agreement

The Green Book & ACH Payments

Personal Deposit Account Agreement and Disclosures Effective April 5, 2016

Business Online Banking Services Agreement

Bank Secrecy Act Credit Union Training for Board Members and other Volunteers. Overview. Overview. Overview of Money Laundering and Financial Crime

TREASURY MANAGEMENT MASTER AGREEMENT TERMS AND CONDITIONS

Check 21 FAQ. Frequently Asked Questions

Old Point ACH Services Annual Training 2014

INSTITUTIONAL CUSTOMER DISCLOSURES

ANTI-MONEY LAUNDERING TRAINING FOR AGENTS TRANSAMERICA LIFE & PROTECTION

Bank Secrecy Act for Volunteers Southeast Leadership Development Conference Destin, Florida November 5, 2015

Bank Secrecy Act 101 Fall Colleen Kelly & Valerie Moss CUNA Compliance

Same Day ACH Progress Report Looking Ahead. Ryan Waterman, AAP, AVP, Risk & Regulatory Compliance

Transcription:

Payment System Rules and Regulations Regional Payments Associations, through their Direct Membership in NACHA, are specially recognized and licensed providers of ACH education, publications and support. Regional Payments Associations are directly engaged in the NACHA rulemaking process and Accredited ACH Professional (AAP) program. NACHA owns the copyright for the NACHA Operating Rules & Guidelines. The Accredited ACH Professional (AAP) is a service mark of NACHA. What will you learn? After this course, you will be able to: Given a scenario, identify the rules and/or regulations that apply to various payment systems Identify the impact and obligations regulations have on your financial institution Respond appropriately to some frequently asked account holder questions Check Regulation J Regulation CC Check 21 UCC 3 UCC 4 Card Association Regulation Z Regulation E Regulation GG OFAC BSA USA Patriot Act ACH ACH Rules Regulation E UCC 4A 31 CFR Part 210 Wire Wire Transfer Regulation J Regulation CC UCC 4A Regulation E Subpart B 3

Check UCC 3 Regulation J Legal framework for check collection through the Federal Reserve Warranties and liabilities Settlement of payments Time schedule and availability Regulation CC Funds Availability Act of 1987 Availability schedules Endorsement standards Disclosure requirements Subpart D Check 21 Substitute check equivalent to original item

UCC 3 Uniform Commercial Code (UCC) Article 3 Rules for paper based transactions Defines negotiable instrument Identifies endorsement types Warranties Transfer Presentment Endorsements Blank Restrictive Special Qualified John Q. Doe For Deposit Only John Q. Doe Pay to the Order of Harry Johnson John Q. Doe Pay to Your Bank Without Recourse John Q. Doe UCC 4 Uniform Commercial Code (UCC) Article 4 Check collection, payment, liabilities, timeframes and responsibilities Late returns Stop payment Special circumstances Outlines relationship with Paying Bank and account holder

Name that Rule or Regulation $25,000 Question(s) Sally Sunshine deposits a $25,000 check from her mother into her checking account. Sally endorses the item For Deposit Only Sally Sunshine. The teller informs Sally there will be a 7 day hold on the item and provides her with an exception hold form. $25,000 Question(s) What rules and/or regulations apply in this scenario? What type of endorsement is it?

ACH ACH Rules Commercial ACH transactions Contract law Developed and maintained by NACHA Operating Guidelines Regulation E Electronic Fund Transfer Act Consumer protections Includes consumer debit ACH transactions

Regulation E Error resolution Consumer notification within 60 days of statement Provisional credit Resolution within 10 days or provide provisional credit Exceptions and special circumstances Regulation E, Subpart B Consumer-Initiated International Remittance Disclosure requirements Ability to cancel Refund requirements Error resolution Safe harbor clarification UCC 4A Governs wholesale credits including CCD and CTX transactions Commercially reasonable security measures Disclosures required by ACH Rules ODFI RDFI

31 CFR Part 210 Federal government s ACH rules Benefit payments, vendor payments and IRS refunds Green Book Procedures manual for financial institutions processing federal government payments Name that Rule or Regulation Send it Back John Black notices an ACH credit on his statement that is not his. The credit is from the IRS with an entry description of Tax Refund. John wants the credit returned to the IRS.

Send it Back What rules and/or regulations apply in this scenario? Card Regulation Z Card Association Rules Facilitate authorization, clearing and settlement Ensure secure processing Rules and regulations Creation, enforcement and standards Dispute resolution Merchant acceptance Physical card design

Regulation Z Credit Cards Truth in Lending Act Required disclosures Right to cancel Resolution to billing disputes Interest rates Regulation E Electronic Fund Transfer Act Rights, liabilities and responsibilities Consumer protections Debit/ATM transactions Financial institution responsibilities Disclosures Statements Stop payments Error resolution Regulation E Error resolution Consumer notification within 60 days of statement Provisional credit Resolution within 10 days or provide provisional credit Exceptions and special circumstances

Name that Rule or Regulation Turn it Off Bill has a recurring debit on his statement for a monthly TV subscription. The transaction is processed with information from his debit card. He comes into your institution and tells you he does not want the debit to hit his account anymore. Turn it Off What rules and/or regulations apply in this scenario?

Wire Transfer Regulation J, Subpart B Check Collection and Funds Transfer Act Establishes procedures, duties and responsibilities of Federal Reserve Bank, sender and recipients Incorporates certain provisions of UCC 4A Directs FRB to issue operating circulars Regulation CC Expedited Funds Availability Act of 1987 Requires immediate availability to Beneficiary

UCC 4A Uniform Commercial Code (UCC) Article 4A Governs wholesale credits Unique payment method with unique rules Commercially reasonable security Regulation E, Subpart B Consumer-Initiated International Remittance Disclosure requirements Ability to cancel Refund requirements Error resolution Safe harbor clarification Name that Rule or Regulation

Truck Load Size Grocery Bill The local grocery store needs to send a $100,000 to a supplier immediately. The supplier will not let the truck driver unload the produce before receiving the funds. Truck Load Size Grocery Bill What rules and/or regulations apply in this scenario? All Payment Systems

Regulation GG Unlawful Internet Gambling Enforcement Act Prohibits business from accepting payment in connection with unlawful Internet gambling Requires financial institutions to identify and block payments OFAC Office of Foreign Assets Control Administers and enforces economic and trade sanctions against targeted foreign countries, terrorism sponsoring organizations and international narcotics traffickers Requires financial institutions to take the appropriate steps to investigate, suspend, reject, block and report on transactions as necessary Written compliance policy and procedures manual OFAC Report all blocked transactions within 10 business days of occurrence Annual report of all property blocked as of June 30 each year is due to OFAC by September 30 Retain reports for 5 years Visit website at www.treas.gov/ofac

BSA Bank Secrecy Act Implemented to deter money laundering Financial institution requirements Obtain proper taxpayer ID number for all deposit accounts File Currency Transaction Report (CTR) for any currency transaction over $10,000 Aggregate during business day File Suspicious Activity Report (SAR) USA Patriot Act Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 Verify the identity of any person seeking to open an account Maintain record of the information used to verify identity Consult government or suspected terrorist lists Name that Rule or Regulation