bankoh business connections wire transfer guide

BANKOH BUSINESS CONNECTIONS WIRE TRANSFER GUIDE
Revision 2/2013
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Contents
GENERAL INFORMATION ............................................................................................. 3
Wire Transfers .................................................................................................................... 3
Types of Wires ................................................................................................................ 3
Wire Templates ............................................................................................................... 3
Bankoh Business Connections Wire Cut-off Times ....................................................... 3
HOW TO CREATE A SINGLE USE WIRE (NON-REPETITIVE) ................................. 4
HOW TO CREATE A WIRE TEMPLATE (SEMI-REPETITIVE) .................................. 6
HOW TO USE A WIRE TEMPLATE (SEMI-REPETITIVE) .......................................... 9
HOW TO APPROVE A WIRE ........................................................................................ 13
HOW TO RELEASE A WIRE ......................................................................................... 14
HOW TO CHECK THE STATUS OF YOUR WIRE...................................................... 15
HOW TO MODIFY A WIRE ........................................................................................... 16
HOW TO DELETE A WIRE ........................................................................................... 16
WIRE HISTORY .............................................................................................................. 17
WIRE APPLICATIONS ................................................................................................... 18
Non-Repetitive Fed Wires ................................................................................................ 18
Non-Repetitive Foreign Currency..................................................................................... 20
Non-Repetitive International USD ................................................................................... 22
Non-Repetitive Tax ........................................................................................................... 24
Non-Repetitive Internal .................................................................................................... 25
Semi-Repetitive Fed.......................................................................................................... 26
Semi-Repetitive Foreign Currency ................................................................................... 28
Semi-Repetitive Intl USD ................................................................................................. 30
Important Notice Regarding Wire Transfers .................................................................... 32
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GENERAL INFORMATION
Wire Transfers
Wire transfers are electronic payments which can be sent to companies and individuals
with an account at a bank. Most wire transfers are sent through the Federal (FED)
Reserve Wire Network or the Society for Worldwide Interbank Financial
Telecommunication network (SWIFT) or the Clearing House Interbank Payments System
(CHIPS). Most banks use special codes and an address to identify themselves in the
payment network. Most US banks use an ABA Routing Number while most Non-US
Banks use a SWIFT code, however, some banks may have both. Additionally, some
banks have a CHIPS code.
Fed ABA Wire Directory - http://www.fededirectory.frb.org/search.cfm
Types of Wires
The basic types of wires available in Bankoh Business Connections include: Fed, Foreign
Currency, International US Dollar (Intl USD), and Internal (also known as Book) wire.
• Fed wire transfers - are used to send payments to US banks in US Dollars.
• Foreign Currency wire transfers - are used to send payments in Foreign Currency
most often to Non-US banks.
• Intl USD wire transfers - are used to send payments in US Dollars to a Non-US
bank.
• Internal (Book) wire transfers – are used to send payments in US Dollars from
your Bank of Hawaii account to another account at Bank of Hawaii.
Wire Templates
In Bankoh Business Connections (BBC), you can send a one-time wire or choose to set
up a template if you plan to send the wire to the same destination on a frequent basis:
• Non-Repetitive Wire – one-time use, no template created.
• Semi-Repetitive Wire – a wire template is created and saved. Once the template
is created and saved, you will only be required to enter the amount and the value
date.
• Repetitive Wire – a wire template is created and saved. Once the template is
created and saved, you will only be required to enter the value date.
Bankoh Business Connections Wire Cut-off Times
•
•
•
Fed (Domestic)
Foreign Currency (incl. Intl USD)
Internal (Book)
11:30 AM Hawaiian Standard Time
1:30 PM Hawaiian Standard Time*
4:00 PM Hawaiian Standard Time
Wire Transfers received after the cut-off times above will be processed the next business
day.
*Note: Foreign Currency wires must be sent the same day.
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HOW TO CREATE A SINGLE USE WIRE (NON-REPETITIVE)
1) Click on “Wire Transfers” from the left hand navigation bar
2) Click on “ Single Wire”
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3) Click on the type of wire you would like to send (e.g. Non-Rep Fed, Non-Rep
Foreign Currency, etc.) Note: Not all wire types may be available to you
depending upon your set up in Bankoh Business Connections.
4) After completing the required fields for the wire (see WIRE APPLICATIONS
section for details on the fields), click “Queue”.
5) As part of the security features built into BBC, the person who enters the wire
cannot release it, so another user with wire release authority must login and
release the wire (see HOW TO RELEASE A WIRE). Additionally, if your setup
requires wires to be approved, another user with wire approve authority must
approve your wire before it can be released (see HOW TO APPROVE A
WIRE).
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HOW TO CREATE A WIRE TEMPLATE (SEMI-REPETITIVE)
1) From the dashboard, click “Setup”
2) On the left hand menu and then click on “Manage Wire Templates”.
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3) Click “Add Template”
4) Click the drop down menu and select the wire template type you wish to create
and click “Continue”
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5) After completing the required fields for the wire (see WIRE APPLICATIONS
section for details on the fields), click “Save”.
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HOW TO USE A WIRE TEMPLATE (SEMI-REPETITIVE)
1) Click on “Wire Transfers” from the left hand navigation bar
2) Click on “ Single Wire”
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3) Click on the type of semi repetitive (e.g. Semi-Repetitive Fed, Semi-Repetitive
Foreign Currency, etc.) wire you would like to send. Note: Not all wire types may
be available to you depending upon your set up in Bankoh Business Connections.
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4) Click the
button view the list of the templates available.
5) Select a template from the list by clicking it and then click “OK”.
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6) The selected template will now appear in the “Template ID” field. Fill in the
appropriate fields in the wire template and click the “Queue” button. For
additional information on the wire template fields see WIRE APPLICATIONS.
7) As part of the security features built into BBC, the person who enters the wire
cannot release it, so another user with wire release authority must login and
release the wire (see HOW TO RELEASE A WIRE). Additionally, if your setup
requires wires to be approved, another user with wire approve authority must
approve your wire before it can be released (see HOW TO APPROVE A
WIRE).
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HOW TO APPROVE A WIRE
If your setup in BBC requires each wire to be approved, another user with approval
authority must log in after the wire has been entered to approve the wire and then the
wire can be released (see HOW TO RELEASE A WIRE).
1) In the Wire Transaction List, check the box next to the wire you wish to approve
and click the “Approve” button.
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HOW TO RELEASE A WIRE
After creating a one-time wire or creating a wire using a template, it must be released
for processing. To release the wire:
1) From the dashboard, click “Wire Transfers”.
2) The main Wire Transfer screen will by default show the wire Transaction List,
however, if you are already logged in, you may need to click “Transaction List’.
3) Click the check box next to the wire to be sent and click the “Release” button.
4) You will then be prompted to enter your one time passcode from your security
token. Please enter your passcode into the popup window and click “OK”.
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HOW TO CHECK THE STATUS OF YOUR WIRE
Once a wire has been entered and released into BBC, you may check the status of the
wire by clicking on “Wire Transfers” and then “Transaction List”. If you are
monitoring the processing of a wire, you may click the “refresh” button in your web
browser or press the “F5” button on your keyboard to update the Transaction List screen.
Below are wire status descriptions and user actions required, if applicable.
Status
*Entered
*Approved
*Pending
Pending Release
Release
Acknowledged
Processed
Rejected
Description
Wire data has been entered
into BBC
Wire has been approved in
BBC
Wire is being processed in
BBC
Wire is in the process of
being sent to BOH Wire
System
Wire has been sent to BOH
Wire System
Wire has been received by
BOH Wire System
Wire has been processed
and sent by the BOH Wire
System
An error has occurred.
Voided
Revised
Not “Released” timely
Change made to wire in
Queue
*Requires actions by authorized user.
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Next Action Required by
User
Release (or Approve if
required)
Release (or Approve if
required)
None. However, if wire
remains in this status, and
does not progress to the
next stage, you many need
to contact Cash
Management for assistance
None
None
None
None
Please contact Cash
Management for assistance
None
None
HOW TO MODIFY A WIRE
If a wire has been entered but not approved or released, you can modify it before it is
sent for processing.
1) Navigate to the Wire Transaction List by clicking on “Wire Transfers” and the
“Transaction List”.
2) Click the box next to wire you wish to modify and then click “Revise” button.
3) Click “Wire Repair” from the upper navigation menu.
4) The wire will then appear in the Wire Repair list. Click on the amount of the wire
(hyperlink in blue).
5) You can then modify the wire as necessary and then click “Queue” button to
continue. Please note that the wire will then need to be approved or released for
processing.
HOW TO DELETE A WIRE
If a wire has not been released for processing, you can delete it.
1) Navigate to the Wire Transaction List by clicking on “Wire Transfers” and the
“Transaction List”.
2) Click the box next to wire you wish to modify and then click “Delete” button.
3) A popup box will ask you to confirm that you wish to delete the wire. Click
“OK” to confirm deletion.
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WIRE HISTORY
You can review the wires you have sent previously by clicking “Wire History” from the
top navigation bar. The wire history screen will list your wires sent within the past 45days.
You may also perform a search by entering the appropriate wire data in the search fields
and by clicking “Search”.
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WIRE APPLICATIONS
Non-Repetitive Fed Wires
FIELD
Amount*
Value Date
Debit Account*
Receiving Bank ID*
Receiving Bank Name*
Receiving Bank Address
Beneficiary Account*
Beneficiary Name
Beneficiary Address
DATA TO ENTER
Amount in US dollars
Wire Date (default is current business date)
Account to be debited for the wire. If you have multiple
accounts, click the drop down menu and select the desired
account.
Enter the ABA number for the receiving bank. (Tip: You
can search for the number by clicking the
button.)
Enter the name of receiving bank. (Tip: You can search
for the name by clicking the
button.)
Enter address, city or branch of receiving bank.
Enter the account number to be credited.
Enter the name of the customer to be credited.
Enter address of the customer to be credited.
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Non-Repetitive Fed Con’t
FIELD
Reference for Beneficiary
OBI
(Other Beneficiary Info)
BBI
(Bank to Bank Info)
DATA TO ENTER
Optional reference field for sender to use or Leave Blank
Optional field for sender to communicate to customer to
be credited or Leave Blank
Optional field used to send info to beneficiary bank or
Leave Blank
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Non-Repetitive Foreign Currency
FIELD
Contract Number
Amount*
Sending Currency*
Exchange Rate*
Sending Currency Amount
Value Date*
Debit Account*
Receiving Bank ID Type
Receiving Bank ID
Receiving Bank Name*
Receiving Bank Address*
DATA TO ENTER
Leave blank
Amount in US dollars
Click drop down to choose foreign currency
This will automatically be filled in after selecting the
foreign currency above
This will automatically be filled in after selecting the
foreign currency above
Wire Date (default is current business date)
Account to be debited for the wire. If you have multiple
accounts, click the drop down menu and select the desired
account.
Click drop down and select “SWIFT BIC”
Enter SWIFT BIC code for the receiving bank.
Name of the receiving bank.
Enter Address, City or Branch of Bank
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Non-Repetitive Foreign Currency Cont’d
FIELD
Beneficiary Account*
Beneficiary Name
Beneficiary Address
Reference for Beneficiary
OBI
(Other Beneficiary Info)
BBI
(Bank to Bank Info)
DATA TO ENTER
Enter the account number to be credited.
Enter the name of the customer to be credited.
Enter address of the customer to be credited.
Optional reference field for sender to use or Leave Blank
Optional field for sender to communicate to customer to
be credited or Leave Blank
Optional field used to send info to beneficiary bank or
Leave Blank
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Non-Repetitive International USD
FIELD
Amount*
Currency
Value Date*
Debit Account*
Receiving Bank ID Type
Receiving Bank ID
Receiving Bank Name*
Receiving Bank Address*
Beneficiary Account*
Beneficiary Name
Beneficiary Address
DATA TO ENTER
Amount in US dollars
US Dollar
Wire Date (default is current business date)
Account to be debited for the wire. If you have multiple
accounts, click the drop down menu and select the desired
account.
Click drop down and select “SWIFT BIC” or “ABA”
Enter SWIFT BIC code for the receiving bank.
Name of the receiving bank.
Enter Address, City or Branch of Bank
Enter the account number to be credited followed by
USD. Example: “12345678USD”.
Enter the name of the customer to be credited.
Enter address of the customer to be credited.
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Non-Repetitive International USD Con’t
FIELD
Reference for Beneficiary
OBI
(Other Beneficiary Info)
BBI
(Bank to Bank Info)
DATA TO ENTER
Optional reference field for sender to use or Leave Blank
Optional field for sender to communicate to customer to
be credited or Leave Blank
Optional field used to send info to beneficiary bank or
Leave Blank
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Non-Repetitive Tax
FIELD
Tax Type Code*
Tax Amount*
Interest Amount
Interest Amount
Total Amount
Currency
Value Date*
Tax Year*
Tax Month*
Contact Name
Telephone Number
Tax ID Number*
Taxpayer Name Control*
Taxpayer Name
DATA TO ENTER
Select the Tax Type by clicking the
button
Amount in US dollars. Note: If you select Tax Type Code
for 720, 941 or CT-1 payment, you will see additional
Amount, Subcategory or Abstract Number fields. Fill in
any required fields marked with an “*”.
Amount in US dollars (in required)
Amount in US dollars (in required)
Total Amount is automatically calculated
US Dollars
Wire Date (default is current business date)
Tax Year in 2-digit format (i.e. 2012=12)
Tax Month in 2-digit format (i.e. February=02)
Contact Name
Telephone Number
Tax ID Number
Taxpayer Name Code provided by IRS. Note: This is a 4digit alphanumeric code.
Taxpayer name
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Non-Repetitive Internal
FIELD
Amount*
Currency
Value Date*
Debit Account*
Beneficiary Account*
Beneficiary Name
Beneficiary Address
INF
DATA TO ENTER
Amount in US dollars
US Dollar
Wire Date (default is current business date)
Account to be debited for the wire. If you have multiple
accounts, click the drop down menu and select the desired
account.
Enter the Bank of Hawaii account number to be credited.
Enter the name of the customer to be credited.
Enter address of the customer to be credited.
Optional field for additional information
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Semi-Repetitive Fed
FIELD
Template ID*
Description*
Debit Account*
Receiving Bank ID*
Receiving Bank Name*
Receiving Bank Address
Beneficiary Account*
Beneficiary Name
Beneficiary Address
DATA TO ENTER
Create a unique ID for your template (up to 16 alpha
numeric characters). This will identify your template for
future wires.
Create a short description of the template up to 35 alpha
numeric characters). This will help identify your template
for future wires.
Account to be debited for the wire. If you have multiple
accounts, click the drop down menu and select the desired
account.
Enter the ABA number for the receiving bank. (Tip: You
can search for the number by clicking the
button.)
Enter the name of receiving bank. (Tip: You can search
for the name by clicking the
button.)
Enter address, city or branch of receiving bank.
Enter the account number to be credited.
Enter the name of the customer to be credited.
Enter address of the customer to be credited.
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Semi-Repetitive Fed Con’t
FIELD
Reference for Beneficiary
OBI
(Other Beneficiary Info)
BBI
(Bank to Bank Info)
DATA TO ENTER
Optional reference field for sender to use or Leave Blank
Optional field for sender to communicate to customer to
be credited or Leave Blank
Optional field used to send info to beneficiary bank or
Leave Blank
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Semi-Repetitive Foreign Currency
FIELD
Template ID*
Description*
Debit Account*
Sending Currency*
Receiving Bank ID Type
Receiving Bank ID
Receiving Bank Name*
Receiving Bank Address*
Beneficiary Account*
Beneficiary Name
Beneficiary Address
DATA TO ENTER
Create a unique ID for your template (up to 16 alpha
numeric characters). This will identify your template for
future wires.
Create a short description of the template (up to 35 alpha
numeric characters). This will help identify your template
for future wires.
Account to be debited for the wire. If you have multiple
accounts, click the drop down menu and select the desired
account.
Click drop down to choose foreign currency
Click drop down and select “SWIFT BIC”
Enter SWIFT BIC code for the receiving bank.
Name of the receiving bank.
Enter Address, City or Branch of Bank
Enter the account number to be credited.
Enter the name of the customer to be credited.
Enter address of the customer to be credited.
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Semi-Repetitive Foreign Currency Con’t
FIELD
Reference for Beneficiary
OBI
(Other Beneficiary Info)
BBI
(Bank to Bank Info)
DATA TO ENTER
Optional reference field for sender to use or Leave Blank
Optional field for sender to communicate to customer to
be credited or Leave Blank
Optional field used to send info to beneficiary bank or
Leave Blank
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Semi-Repetitive Intl USD
FIELD
Template ID*
Description*
Debit Account*
Receiving Bank ID Type
Receiving Bank ID
Receiving Bank Name*
Receiving Bank Address*
Beneficiary Account*
Beneficiary Name
Beneficiary Address
DATA TO ENTER
Create a unique ID for your template (up to 16 alpha
numeric characters). This will identify your template for
future wires.
Create a short description of the template (up to 35 alpha
numeric characters). This will help identify your template
for future wires.
Account to be debited for the wire. If you have multiple
accounts, click the drop down menu and select the desired
account.
Click drop down and select “SWIFT BIC” or “ABA”
Enter SWIFT BIC code for the receiving bank.
Name of the receiving bank.
Enter Address, City or Branch of Bank
Enter the account number to be credited followed by
USD. Example: “12345678USD”.
Enter the name of the customer to be credited.
Enter address of the customer to be credited.
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Semi-Repetitive Intl USD Con’t
FIELD
Reference for Beneficiary
OBI
(Other Beneficiary Info)
BBI
(Bank to Bank Info)
DATA TO ENTER
Optional reference field for sender to use or Leave Blank
Optional field for sender to communicate to customer to
be credited or Leave Blank
Optional field used to send info to beneficiary bank or
Leave Blank
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Important Notice Regarding Wire Transfers
Before sending payments by wire transfer, ensure the bank routing and beneficiary
account numbers match the vendor payment instructions you have on file and have not
been altered in any way. Be extremely careful when making remittance payments by wire
transfer to foreign countries, as the FBI has issued warnings of an increasing trend of
cyber criminal activity from countries such as China and Russia.
Should your company receive invoices via email, it is highly recommended that the
sender of the email and the invoice be validated using a method other than email before
remitting payment. Validation can be conducted in various ways such as a call back to a
designated contact person or someone known to you at the company to confirm the
accuracy of the emailed payment instructions or verifying that the payment instructions
and mailing addresses on the invoice match existing payment instructions you have on
file for the vendor.
As a reminder, wire transfers from your account are immediate and final payment and
may not be retrievable once they are sent. We recommend that you use extreme caution
when creating and approving wires and report any suspicious transactions immediately to
Cash Management Services at (808) 694-8021 or toll free at 1-877-232-0118.
Cash Management Services Agreement
Use of Bankoh Business Connections Wire Transfer Service is subject to the terms and
conditions of the Cash Management Services Agreement. Your use of the service is
evidence of your agreement to the terms of the Agreement. You agree to comply with the
terms of any software licenses provided to you in connection with the Services. You may
not transfer, distribute, copy, reverse compile, modify or alter such software. Unless
otherwise agreed by us in writing, the computer programs, Service guides, security
procedures, software and systems provided to you in connection with the Services
represent our proprietary property and must be returned to us upon request. Termination
of this Agreement by either party for any reason whatsoever will terminate your license
to use any software we make available to you in connection with a Service. Software
provided by us cannot be used or transferred outside the United States without our written
consent.
Security Procedure and User Guides
We may provide you with one or more identification numbers, passwords, tokens, and/or
other means of identification and authentication (collectively "Password") to access our
Services. We may also provide you with operating procedures and user guides ("User
Guides") in connection with certain Services. You agree to: (a) comply with the User
Guides and procedures that we provide to you; (b) establish, maintain and update
commercially reasonable policies, procedures, equipment and software that will
safeguard the security and integrity of your computer systems and information from
unauthorized use, intrusion, takeover or theft, (c) take reasonable steps to safeguard the
confidentiality and security of the Password, the User Guide, and any other proprietary
property or information we provide to you in connection with the Services; (d) not
provide access to your Password to anyone; (e) closely and regularly monitor the
activities of employees who access the Services; (f) notify us immediately if you have
any reason to believe the security or confidentiality required by this provision has been or
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may be breached; and (g) immediately change your Password if you know or suspect that
the confidentiality of the Password has been compromised in any way. Our security
procedures are not designed for the detection of errors (e.g., duplicate payments or errors
in your fund transfer instructions). We will not be obligated to detect errors by you or
others, even if we take certain actions from time to time to do so.
As an alternative to verifying transactions by means of a Password, we may elect to
verify the authenticity or content of any order or instruction by placing a call to any
authorized signer on your account or any other person designated by you for that purpose.
We may deny access to the Services without prior notice if we are unable to confirm to
our satisfaction any person’s authority to access the Services or if we believe such action
is necessary for security reasons.
Each time you make a transfer or payment with a Service, you warrant that our security
procedures are commercially reasonable (based on the normal size, type, and frequency
of your transactions). Some of our Services allow you or your Administrator to set
transaction limitations and establish internal controls. Your failure to set such limitations
and implement such controls increases your exposure to, and responsibility for,
unauthorized transactions. You agree to be bound by any transfer, instruction or payment
order we receive through the Services, even if it is not authorized by you, if it includes
your Password or is otherwise processed by us in accordance with our security
procedures.
You agree and acknowledge that you bear all risk of fraudulent transfers and other losses
arising from internal security breaches or from the interception of your communications
prior to their receipt by us. We will not reimburse you in connection with any internal
security losses.
Fund Transfer Services
We offer fund transfer Services that allow you to make payments to others, by wire, or
by Internet instruction.
Warranties. You warrant and agree to comply with the terms of the Electronic Funds
Transfer Act if applicable, or Uniform Commercial Code Article 4A (UCC4A) if
applicable, and shall otherwise perform all obligations under this Agreement in
accordance with all applicalble laws and regulations. You agree to comply with U.S. law
in regards to origination of ACH entries or orders including but not limited to sanctions
enforced by the Office of Foreign Assets Control (OFAC). It is you responsibility to
obtain information regarding OFAC enforcement sanctions. You can obtain information
at OFAC’s website http://www.ustreas.gov/offices/enforcement/ofac/ or by telephoning
the OFAC Compliance Hotline at 1-800-540-OFAC.
Orders and Charging Your Account. When you transmit a transfer or payment request
(“Order”), you authorize us to charge the designated account for the amount indicated.
Fund Transfer Instructions. Your Orders must comply with the form, format and other
requirements set forth in your User Guide and any security procedures that we establish
for the Service. We are not responsible for detecting or rejecting duplicate Orders. If you
give us an Order that is incorrect in any way, you agree that we may charge your account
for the payment whether or not the error could have been detected by us.
You must accurately describe transaction beneficiaries, intermediary financial
institutions, and the beneficiary’s financial institution in your Orders. If you describe any
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beneficiary or institution inconsistently by name and number, we and other institutions
may process the Order solely on the basis of the number, even if the number identifies a
person or entity different from the named beneficiary or institution.
If your Order involves a foreign transfer, we may execute the Order in the currency of the
country of the payee’s financial institution at either our buying rate of exchange for U.S.
dollar transfers or the exchange rate of the payee institution. If for any reason the transfer
is returned, you agree to accept the refund in U.S. dollars in the amount of the foreign
money credit, based on the current buying rate on the day of the refund, less any charges
and expenses incurred by us. Foreign transfers may be subject to delays, charges
imposed by other financial institutions, and changes in foreign currency exchange rates.
Available Funds. We may refuse an Order if there are not sufficient collected and
available funds in your account. We may delay execution of the Order until we have
received adequate assurance from you that the funds will be available. Nothing in this
Agreement, nor any course of dealing between us, shall be construed as our commitment
or obligation to lend money to you.
Cancellation and Amendment of Orders. You may not cancel or amend an Order after we
receive it. If we attempt to reverse an Order at your request, we assume no liability for
any interest or losses that result if the reversal is not effected. You agree to indemnify,
defend, hold harmless and reimburse us for all expenses, losses, claims, actions,
proceedings and damages we incur in effecting or attempting to effect any reversal. You
are solely responsible for providing notice to receivers that a reversal is being transmitted
and the reason for the reversal no later than the settlement date of the reversing entry.
Refusal of Orders. We may refuse any Order with or without cause or prior notice. We
will notify you of such refusal electronically, in writing, by telephone, or otherwise no
later than the business day following the date the Order was to be effected.
Notices and Statements. Information on transfers to or from your accounts will be
reflected on your periodic statements and may be available to you on-line. We are not
required to provide you with any other notice of the receipt, transmittal or debiting of
Orders.
Unauthorized Order. We may process any Order (including an amendment or
cancellation Order) we believe is transmitted or authorized by you if we act in
compliance with the security procedure (including any callback procedure) agreed upon
by you and us. Such Orders will be deemed effective as if made by you, and you will be
obligated to pay us in the amount of such Orders, even though they are not transmitted or
authorized by you. We strongly recommend that you impose a dual control environment
in connection with the transmission and confirmation of Orders. If you elect not to do so,
you agree to be subject to a higher standard of care with respect to your accounts,
transactions and statements.
Contingency. In the event you cannot create or transmit an Order due to hardware or
communications outage, it is your responsibility to have contingency procedures in place.
In the event that we cannot process the file through normal channels, every effort will be
taken to find alternate means to process the order. We will not be held liable for delayed
files in any case resulting from hardware or communication outages.
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Audit. You agree to allow and assist us in auditing your data, policies, procedures,
controls, and compliance with the Rules and this Agreement in regard to the Funds
Transfer Services.
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