RDFI Operations

Transcription

RDFI Operations

© 2016 Western Payments Alliance. All rights reserved. No reproduction/distribution without prior written consent.
RDFI Operations
John Curtis, AAP NCP, SVP Education
Connie LaChance, AAP, AVP of Education
Jim Petkovits, AAP, NCP, VP of Education
Patty Presta, AAP, VP, Professional Development Events
Western Payments Alliance
1
WesPay, as a Direct Member of NACHA, is a specially recognized and licensed
provider of ACH education, publications and support. Regional Payments
Associations are directly engaged in the NACHA rulemaking process and the
Accredited ACH Professional (AAP) program.
This material is derived from collaborative work product developed by NACHA ─ The
Electronic Payments Association and its member Regional Payments Associations. This
material is not intended to provide any warranties or legal advice, and is intended for
educational purposes only.
© 2016 Western Payments Alliance (WesPay). All rights reserved.
NACHA owns the copyright for the NACHA Operating Rules & Guidelines.
The Accredited ACH Professional (AAP) is a registered service mark of NACHA.
3
Agenda
» ACH Rules/Regulations for the RDFI
» Daily Processing and Settlement
» RDFI Obligations
» Returns and Notifications of Change
4
2
ACH Rules
» Covers:
• Operating Rules
• Operating Guidelines
» Revisions made annually
• Changes outlined in beginning
of manual
» NACHA Operating Rules
»
considered to be contract law
Formal rules interpretations
found near beginning of
manual
5
ACH Rules (continued)
» Resources page on page OG 358:
• Federal Reserve Operating Circular #4
o
www.frbservices.org/regulations/operating_circulars.html
• Regulation E
http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title
12/12cfr1005_main_02.tpl
• Electronic Federal Tax Collections
o http://tfm.fiscal.treasury.gov/v4/p1/c2000.pdf
• 31 CFR Part 210-Federal Government Participation in the ACH
o http://www.ecfr.gov/cgibin/textidx?rgn=div5&node=31:2.1.1.1.8
• 2016 Federal ACH Payment Schedule
o https://www.fiscal.treasury.gov/fsreports/ref/greenBook/pdf/2
016pay.pdf
o
6
3
Federal Reserve Operating Circular #4
» Governs clearing and settlement of ACH debit and
credit entries
» Incorporates NACHA rules and agreements
» For financial institutions using Federal Reserve as ACH
Operator
7
Regulation E
» From Code of Federal
Regulations
» Covers rules associated with
protecting rights of individual
consumers engaging in
electronic transfers
» Intended to carry out
provisions of Electronic Funds
Transfer Act from 1978
8
4
Uniform Commercial Code Article 4A
» Related to wire and ACH Entries
» Pertains generally to corporate credit Entries only
(CCD/CTX)
» Copy can be found in Regulation J of Federal Reserve
» Requires notice to Receiver
3
4
4A
5
U
C
C
U
C
C
U
C
C
U
C
C
9
Treasury Green Book
» Covers rules governing Federal government payments
» Obtained from US Treasury
• Revised periodically
• http://www.fiscal.treasury.gov/fsreports/ref/greenBook/gre
enbook_home.htm
10
5
Regulation D
» Covers “Reserve Requirements of Depository
Institutions”
» For ACH purposes it helps distinguish between
“transaction” account and “non-transaction” account
» Defines limits for number of ACH transactions that can
go into non-transaction account
11
Agenda
» RDFI Obligations
12
6
Flow of Entries (Data) Between
Participants
Receiving
Originating
ACH
Operator
Could be
one and the
same
ACH
Operator
RDFI
ODFI
Entries (data) moves separately
from funds ($). Credits 2/4 days
prior to settlement date, debits
one day prior
Originator
Authorization from
Receiver
Receiver
13
Receiving Points
ACH Operator
RDFI
ODFI
Originator
Third-Party Service Provider
or Correspondent Financial Institution
Example 1
RDFI = RP
Example 2
3rd Party = RP
Receiver
14
7
Receiving ACH Entries
Buckets can be emptied
whenever Receiving Point
wants their ACH entries
15
Incoming ACH File Contents
» Prenotifications
» Death Notification Entries (DNEs)
» Credit Entries
» Debit Entries
16
8
Incoming ACH File Contents
» Rejected Returns/Notification of Changes (NOCs) that
ACH Operator cannot process
» Dishonored Returns from ODFI
» Refused NOCs for ODFI
» Commercial and Federal Government
17
RDFI Key Data Elements
» Batch Header information
» Trace Number
» Transaction Code
» Routing Number
» Check digit
18
9
RDFI Key Data Elements
» Account number
» Dollar amount
» Customer ID
» Customer name
19
File Processing
» Posting on Settlement Date
» Posting to Receiver’s account number
» Maintaining statement information for Regulation E
» Maintaining record information
» Identifying/processing Addenda Records
» Balancing to settlement information
20
10
RDFI Security
» Insure files received and processed promptly/accurately
» Maintain documented procedures
» Secure ACH input data/limit access by unauthorized
personnel
» Establish/test disaster recovery procedures/contingency
plans
» Maintain backup files
21
Settlement of ACH Entries
» Through Federal Reserve Bank
• Correspondent relationships
» Includes ACH on Fed Statement
22
11
Agenda
» RDFI Obligations
23
Warranty Obligations
» Given to ODFI and ACH Operator
» Indicates RDFI has power to
• receive ACH Entries
• comply with ACH Rules
» Includes indemnification to ODFI and ACH Operator
against loss
24
12
ACH Entry Acceptance Obligations
» Must accept credit, debit and Zero-Dollar Entries that
comply with ACH Rules
• RDFI does maintain right to return under approved
conditions
» Must accept Prenotifications that comply with ACH
Rules
25
Prenotification Obligations
» Must verify account number is for valid account
» Can either accept, reject and return or send Notification
of Change Entry
26
13
Funds Availability Obligations
» Credit entries available no later than Settlement Date*
• Exception: RDFI reasonably suspects Credit is
•
unauthorized (account takeover situation)
Exception: PPD received by 5:00 pm RDFI’s local time—
opening of business availability required
» Debit Entries not posted before Settlement Date
» Warehousing of information may be necessary
27
Disclosure Obligations
» Found in Regulation E and Article Three of 2016
NACHA Operating Rules and Guidelines
» RDFI must provide or make available
» Normally referred to as periodic or monthly account
statement
28
14
Remittance Information Processing
» Applies to CCD, CTX, CIE and IAT (to Non-Consumer
Account) only
» Non-consumer Receiver may request from RDFI to
accurately update its accounts receivable records
» RDFI obligated to provide information by deadline
• Opening of business on second banking day following
Settlement Date
29
Acknowledgment Obligations
» ACH Payment Acknowledgment (ACK) and Financial
EDI Acknowledgment (ATX) Standard Entry Class
Codes
» Optional for all participants
» Indicates that RDFI has received entries and will attempt
to post CCD/CTX credits to Non-Consumer Account
30
15
Audit Obligations
» Found in NACHA Operating Rules - Appendix 8
» Requires RDFI to review 19 topics
•
•
•
•
•
•
•
•
•
Records
Electronic records
Verification of audit from previous year
Unsecured network encryption requirements
Network administration fees paid
Verification of risk assessment
Security policies, procedures and systems
Prenotifications
Notifications of Change
31
Audit Obligations (continued)
» Requires RDFI to review 19 topics (continued)
•
•
•
•
•
•
•
•
•
•
Acceptance of Entries
Settlement with Receivers
Statement information
Returns
Re-presented Check Entry Returns
Credit Entries refused by Receiver
Stop Payments
Written Statements of Unauthorized Debit
Compliance with UCC 4-A
Payment-related information
32
16
Agenda
» RDFI Obligations
33
RDFI Responsibilities for Return
Entries
» Return any Entry that cannot be posted
• Do not put into suspense account
» Use correct Return Code
» Meet proper deadlines
» Include proper information
•
•
•
•
Information from original Entry
New batch and trace numbers
Identification of returning RDFI
Appropriate transaction code
34
17
Stop Payment versus Authorization
Issue
» What is the problem?
• Lack of consumer understanding
• Stop payment originally designed to stop one payment
(debit) only
• Authorization Revoked or Customer Advises Not
Authorized “should” stop Entry permanently
35
Notification of Change Definition
» An ACH Entry that:
• is Non-Monetary Entry sent by RDFI
• is generated in response to Prenote or live Entry
containing incorrect information
• tells Originator there is problem with contents of ACH
Entry
• provides Originator with specific information to correct
ACH Entry
36
18
Available Publications for More
Information
» 2016 ACH Rules (print version or on CD!)
• Print version, on CD or on-line
» ACH Compliance Manual—How to Comply with ACHRelated Rules
Available at www.wespay.org
37
Questions?
38
19
Questions? Please contact us at:
300 Montgomery St, Suite 400
San Francisco, CA 94104
Phone: 415-433-1230
Fax: 415-433-1370
www.wespay.org
[email protected]
Payments Hotline - 415-373-1200 or [email protected]
Participants from other Regional Payments Associations are encouraged to contact your Regional
Payments Association directly. You can find them here: www.nacha.org/regpayassoc
39
Thanks for Participating
PLEASE – Complete your evaluation.
40
20

RDFI Operations

Transcription

Similar documents

I`m helping to end MS by participating in the 2016 Jayman BUILT MS

Workout your financial future New life, new ride Interest rates

2009 - Alliance Community Hospital

The Board of Directors of Qatar Fuel (WOQOD) is pleased to invite

Navigating the McKendree Website

5 `S` Training Program at ABV-IIITM, Gwalior on 21.07.2016

Speech of the Prime Minister

Paymentez User How To Guide en

Porky Expo Flyer

2012MAR6 BGI-PPI Press Release Intl.