Operating Procedures/Guide - PDF Free Download

HOME SPECIALTY STANDARD OPERATING PROCEDURES Operating Procedures/Guide Effective Date 8/19/2014 Credit is extended by Synchrony Bank.

Table of Contents Introduction...................................... 3 Program Management................................3 Procedures.......................................4 Sales Associate Credit Card Training.....................4 Training Audience.................................4 Credit Advertising/Marketing......................... 5 Application Processing............................. 5 Offering Credit Application.........................5 Disclosures.................................. 5 Retention Requirements...........................6 E-Sign Requirements.............................6 Privacy..................................... 6 Eligibility....................................6 Account Structure.............................. 7 Customer Identification...........................7 Application Channels.............................7 Employee Incentive (SPIFF).........................8 Transaction Processing............................. 8 Requirements.................................8 Standard Transactions............................9 Offering Special Financing......................... 9 Special Financing Disclosures....................... 9 Retention Requirements...........................9 E-Sign Requirements.............................9 Account Access............................... 10 First Purchase Discount.......................... 10 Voided Authorizations........................... 10 Card Not Present.............................. 10 Fraud Prevention and Identity Theft................... 10 Preventing Chargebacks......................... 11 Account Truncation............................. 11 Customer Service..................................12 Cardholder Servicing..............................12 Escalations....................................12 Direct Customer Inquiries...........................12 Lost or Stolen Cards..............................12 Operating Procedures/Guide Home Specialty 1

2 Operating Procedures/Guide Home Specialty

INTRODUCTION This credit program Operating Guide is provided by Synchrony Bank and will serve as a reference guide to effectively administer the Synchrony Bank credit card program (the Program ). This Operating Guide supplements your Card Acceptance Agreement for Participating Merchants (the Card Acceptance Agreement ). The Card Acceptance Agreement will control to extent that there are discrepancies between this Operating Guide and the Card Acceptance Agreement. Synchrony Bank Contact Information For questions regarding your Synchrony Bank financing program, call Merchant Services at 888-222-2176 or contact your Synchrony Bank representative. PROGRAM MANAGEMENT Synchrony Bank and its credit programs must operate in adherence to applicable law and regulatory requirements including those noted in this Operating Guide. All bank and retail procedures, operations and employee training related to the Program must comply and reinforce these requirements. The Program must be offered to customers in a fair and consistent manner. Training and management must ensure employees do not discourage anyone from submitting an application, either through oral statements, body language, delays or discourtesy. Also, make certain that employees provide a consistent level of service in responding to questions from consumers about the availability of credit and/or completing the application. Procedures, practices, and materials relating to the administration and execution of the Program must be designed to provide consumer clarity about the terms and conditions of the Synchrony Bank credit card. Misrepresentation or inadequate disclosures of material terms could mislead a consumer and be determined to be a deceptive practice. As part of Synchrony Bank s on-going review of the Program, process and system surveillance and/or mystery shopping may be conducted. Operating Procedures/Guide Home Specialty 3

PROCEDURES Sales Associate Credit Card Training All employees, including sales associates and management, must receive adequate training about the Program, including: Operational instructions for processing applications and sales transactions, including data and disclosure requirements. Product knowledge about the promotions offered under the Program. How to offer credit compliantly. This training must provide guidance on how to offer credit with respect to consumer protection and regulatory expectations, including but not limited to Fair Lending, Privacy, UDAAP, Patriot Act, Card Act, Truth in Lending, Reg. B, Reg. C and Reg. Z. Retraining as needed based on customer feedback and escalated complaints. Any training documentation prepared by Merchant and related to the Program should be submitted to Synchrony Bank for review and approval. Synchrony Bank will make available via online courses on the Learning Center site at www.mysynchrony.com/learningcenter. Every customer-facing employee should view the list of courses on the Where to Start page on that training website, and review the Orientation Guide training materials that are included in your Welcome Kit. Contact your Synchrony Bank representative if you need a new Orientation Guide. Training audience Managers Credit Materials and Applications (must be current) Spiff Guidelines Fees cannot be passed on to customer Data security Credit Advertising (if applicable) Sales Associates Offering credit Promotional Financing Offers Completing application 4 Operating Procedures/Guide Home Specialty

Credit Advertising/Marketing Advertisement or marketing of the Program, including program features and benefits, via any channel (such as print, radio, television, website, signage, emails, direct mail, social media and point of purchase, etc.), is subject to applicable laws and regulations that provide specific guidance about how to promote such financing programs. Merchant will ensure that credit-related advertising and other disclosures or processes applicable to the Program created by the Merchant comply with all applicable law. All materials referencing financing programs may be subject to review by Synchrony Bank. Should an area of concern be identified, Synchrony Bank will notify and work directly with Merchant to address the issue. As directed by Synchrony Bank, Merchant will either (a) submit any credit related advertising and disclosure applicable to the Program for prior review by Synchrony Bank (pursuant to a review process developed by Synchrony Bank); (b) follow the most current versions of advertising templates provided to Merchant by Synchrony Bank, and in either case, (y) use Synchrony Bankapproved advertising, templates, and other disclosures or processes in the manner directed by Synchrony Bank. Your representative will inform you if Synchrony Bank needs to review some or all advertising in advance. Refer to Synchrony Bank Advertising Guidelines for further guidance. Those guidelines can be found on Business Center at www.mysynchrony.com/business. Contact your Synchrony Bank representative with questions. Application Processing Offering Credit Application All customers should be encouraged to apply for credit without regard to any basis prohibited by law. In addition, credit related activities must be conducted in a way that is not considered unfair, deceptive, or abusive. This includes the requirement that discussions about the credit program, including the offering of credit, are conducted in the same language as the account opening terms and conditions. All completed customer applications must be submitted to Synchrony Bank. No system edits should prevent an application from reaching Synchrony Bank. Customers must understand that the account they are applying for is a credit card. Disclosures The Truth in Lending Act and Regulation Z govern the disclosure of certain credit terms to consumers. Customers must receive the most recent version of the Synchrony Bank Account Opening Disclosures, including Synchrony Bank s privacy policy, in writing prior to the first transaction under the Program to allow them to understand the credit agreement they are entering into with Synchrony Bank. Specifically, every customer must receive and be given the opportunity to review the Account Opening Disclosures prior to signing the credit application and making a purchase. All Merchant application channels must ensure that the Account Opening Disclosures are presented to consumers utilizing Synchrony Bank approved templates. The cardholder s Operating Procedures/Guide Home Specialty 5

acknowledgement and acceptance of the account opening disclosures must be captured (paper or electronic) and retained. This acknowledgement must be presented above (or immediately before) the signature line. The most current version of the Synchrony Bank credit application and Account Opening Disclosures must be provided to customers prior to submitting an application for credit. Utilization of earlier or different versions of the application and Account Opening Disclosures is not permissible, unless specifically instructed by Synchrony Bank. A reliable process must be in place to replace all outdated applications and Account Opening Disclosures at the prescribed date and time. This includes all application and transaction channels. Retention Requirements Documents/data collected during the application process must be retained for no less than 25 months in a secure location. Please see your Card Acceptance Agreement for additional retention requirements. E-Sign Requirements E-signature processes must comply with The Electronic Signatures in Global and National Commerce Act (E-Sign Act). Merchants that want to provide Account Opening Disclosures or promotional disclosures utilizing electronic methods must have the prior written permission of Synchrony Bank. Privacy Data received in the processing of credit applications is subject to the Gramm-Leach-Bliley Act which requires the establishment of administrative, technical, and physical safeguards to (i) ensure the security and confidentiality of customer information, (ii) protect against any anticipated threats or hazards to the security or integrity of customer records, and (iii) protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to any customer. Merchant may not use application information for any purpose other than for the Program. Eligibility Applicants must: Be 18 years or older Have a valid Social Security number Have a current U.S. address (physical street required) Notes: Commercial applications are not accepted Primary applicants must own and reside at property to be improved (no rental properties) A co-applicant should sign the application only if he/she wishes to be obligated to repay the debt. It is the customer s choice whether or not to have a co-applicant. 6 Operating Procedures/Guide Home Specialty

Account Structure Accounts are opened in a single account-holder s name. Joint accounts are available. One account per property (household) in a 60 day period. No split financing of purchases between lenders or account-holders. Customer Identification Applicant and co-applicant (if applicable) identification must be checked and verified (Synchrony Bank does not require or advocate the photocopying customer identification). Two forms of non-expired ID (one primary and one secondary, or two primary) are required at the time of application. Primary ID Must contain customer s photo State Issued Driver s License (Preferred) Government issued ID State Issued ID Passport Military ID Government issued Green/Resident Alien Cards Secondary ID Must contain customer s name and expiration date Visa, MasterCard, American Express, Discover credit or debit card Department store or oil company credit card The most effective way to prevent fraud is to know your customer. If proper identification is not obtained, Merchant will be subjected to chargebacks if the account is later identified as fraudulent. If you suspect fraud, contact Synchrony Bank Merchant Services at 888-222-2176 and inform the operator that you have a Code 10. The operator will guide you with further instructions. Application Channels Application channels supported by Synchrony Bank are in-store via Business Center; in-home via the mobile app; and Internet. All channels must be certified and approved by Synchrony Bank prior to being placed in production. Mobile device or Internet applications (if applicable) must be hosted by Synchrony Bank. Any changes to Merchant systems that could impact application processes must be fully tested to ensure critical disclosure processes have not been compromised. Merchants may not use third party vendors to host application websites, to take applications, or otherwise handle/use consumer information from credit applications, without discussion with, and approval from, Synchrony Bank. Operating Procedures/Guide Home Specialty 7

Merchants looking to accept applications and transactions via any method other than in-store or in-home (e.g., telephone, Internet, mobile app, etc.) must obtain prior written approval from Synchrony Bank. These channels have unique regulatory requirements that must be met. See your Synchrony Bank representative for details. See your Orientation Guide for acceptable and detailed application procedures. Employee Incentive (SPIFF) Synchrony Bank must be made aware of any employee incentive program or contests that involve the credit program. Any employee incentive program related to credit applications must be designed to pay on credit applications processed and not just those that are approved. Synchrony Bank requires incentives to be modest and available to all employees (per level). Incentives may reward an individual, team, location, district, or region and may also include minimum qualifiers (e.g., minimum # of applications). Any Merchant program that involves chance or a selection of winner(s) could be deemed a sweepstakes and requires additional review and approval by Synchrony Bank. Incentives for add on products or same day activation are prohibited. This guidance applies regardless of which entity funds the program. Transaction Processing Requirements All sales that are processed through the program must be for the sale of an approved product or service. Customers must receive products Customers must receive all products and services prior to the date of funding unless expressly approved in Card Acceptance Agreement. All transactions posted to a Synchrony Bank account require an authorization or may be subject to chargeback. All financing transactions must be conducted in compliance with all applicable laws and regulations. Your Card Acceptance Agreement prohibits establishing a minimum or maximum purchase amount (unless otherwise specified for special financing options), adding a surcharge for a credit transaction, or passing along the retail discount fees to customers. In addition, Merchant may not require the purchase of supplemental products as a condition of obtaining credit under the Program. Returns, if financed on the Synchrony Bank credit card, must be credited to the Synchrony Bank credit card. 8 Operating Procedures/Guide Home Specialty

Standard Transactions Standard transaction disclosures are provided in the Account Terms and Conditions. Obtaining a customer s signature is required. Customers must be provided a copy of the Sales Slip. Offering Special Financing Merchants may choose which special financing menu they offer their customers. All customers must be provided all special financing offers within the menu consistently and without bias. Associates who offer financing must be able to accurately describe account and special financing features in a clear and consistent manner. Special Financing Disclosures See your Orientation Guide for detailed processes for communicating all necessary disclosures to the customer. Promotional disclosures ( Advanced Promotional Disclosures ) must be in writing; be clear and conspicuous; and must be provided before the customer obligates themselves. These disclosures can be found on the Synchrony Bank Sales Slips. Critical promotional disclosure data elements must be provided for each promotional transaction. These data elements must be received directly from Synchrony Bank s systems. All Merchant transactional channels must ensure that these disclosures are presented to consumers utilizing Synchrony Bank approved templates. The customer s documented receipt of the Advanced Promotional Disclosure is required. This acknowledgement must be presented above (or prior to) the signature line. Customers must receive a copy of the disclosures in writing. Merchants must ensure that consumers are receiving current copies of all disclosures, and have an established process to ensure that disclosures are updated when advised by Synchrony Bank. Retention Requirements Documents/data collected during the transaction process must be retained for no less than 25 months in a secure location. Please see your Card Acceptance Agreement for additional retention requirements. E-Sign Requirements E-signature processes must comply with The Electronic Signatures in Global and National Commerce Act (E-Sign Act). Merchants that want to provide Account Opening Disclosures or promotional disclosures utilizing electronic methods must have the prior written permission of Synchrony Bank. Operating Procedures/Guide Home Specialty 9

Account Access Synchrony Bank Credit Cards can only be used by the person whose name is embossed on the card. Each person, including authorized users, will have their own card with their name embossed on the card. First Purchase Discount Merchants offering first purchase discounts must work with their Synchrony Bank representative to ensure all regulatory requirements are being met. Voided Authorizations If an authorization on a Synchrony Bank account needs to be voided, (IE: the customer requests to void the authorization or an error was made during the authorization process) the Merchant should contact Synchrony Bank at 888-222-2176 for assistance. Synchrony Bank relies on the Merchant representation that it is appropriate to remove the authorization. A credit to the Synchrony Bank credit card is to be given only when a customer returns merchandise that was initially purchased on the Synchrony Bank credit card. Card Not Present [Telephone/Internet] Telephone and Internet transactions cannot be processed unless Synchrony Bank has provided Merchant prior written approval. If Synchrony Bank approves such transactions, it may issue supplemental requirements for those channels. Card not present transactions pose significant risk to the Merchant as there is no way to verify that the person presenting the card number is actually the cardholder. Therefore, if the cardholder disputes the particular transaction, it will result in a chargeback to the Merchant. Card Not Present [In-store] In-store card not present transactions are permitted as long as Synchrony Bank account number lookup processes are followed. See your Orientation Guide for instructions. Caution should be exercised as card not present transactions pose significant risk to the Merchant because, if disputed by the cardholder, the transaction is subject to chargeback. A primary ID must also be verified for any transactions when the credit card is not present. Fraud Prevention and Identity Theft If Fraud is suspected, contact Merchant Services immediately at 888-222-2176. You can tell the Merchant Services representative that you have a Code 10. This is to avoid alerting the customer that you suspect a possible fraud situation. Several pieces of information will be verified and the representative may request to speak to the customer to verify information listed on the application matches that found in credit bureau. 10 Operating Procedures/Guide Home Specialty

Here are some common warning signals that may indicate a possible fraud situation: Customer s ID is altered, cut, taped, etc. Signature on receipt or application doesn t appear to match signature on ID Photo on ID doesn t look like the customer Customer s address doesn t match their driver s license state The purchase size, quantity, etc. seems abnormal (e.g., multiple purchases of the same item) Preventing Chargebacks Chargebacks occur for many reasons. By adhering to the terms of your Card Acceptance Agreement, the possibility of receiving a chargeback is minimized. The following is a list of the most common reasons for chargeback occurrences: Processing a transaction without obtaining an authorization. Returned merchandise is refused where a refund policy is not properly disclosed on a sale draft or invoice. Signature on the draft does not match the signature on the card. Failure to follow customer identification guidelines when accepting credit applications. Job is not completed and/or merchandise is not delivered Customer has a complaint against quality of product or service delivered Account Truncation The expiration date (or any part thereof, e.g. month or year) and no more than the last five digits of the credit card number can be displayed on any electronically printed receipt provided at the point of sale. Operating Procedures/Guide Home Specialty 11

CUSTOMER SERVICE Cardholder Servicing To provide customer convenience, the following cardholder servicing activities can be conducted: Account Number Lookup: Synchrony Bank Customer Service will request information such as customer name, SSN and zip code prior to providing customer account number to sales associate. Except as outlined above, Synchrony Bank employees may not provide account information to sales employees without the direct consent of the cardholder. For additional servicing, cardholders may be directed to Synchrony Bank via the phone number on the back of the credit card or directed to mobile and online servicing. Escalations Any complaints received from a cardholder or regulatory agency should promptly be referred to Synchrony Bank. Except as noted in this Operating Guide, all other customer servicing functions will be performed by Synchrony Bank customer service. Direct Customer Inquiries to Synchrony Bank Primary cardholders will receive an itemized billing statement monthly that includes a return address envelope for payments. The payment address can also be found by calling Cardholder Customer Service. Customer payments may be made by: Mailing a check or money order. Over the phone through our automated system by calling Cardholder Customer Service (a service fee may be applied). NOTE: Fee will only apply if speaking with a Customer Service Representative. Online through the Consumer Center website (http://consumercenter.mysynchrony.com). Lost or Stolen Cards Cardholders may report lost or stolen Synchrony Bank credit card 24 hours a day, seven days a week to Cardholder Customer Service. If a customer reports a lost or stolen card and does not have the account number, perform an account lookup. Ask the customer for valid identification for verification prior to calling Cardholder Customer Service to assist the customer in reporting the card lost or stolen. 12 Operating Procedures/Guide Home Specialty