Protect Yourself from Your Customer Kristin A. Stedman, AAP
Senior Vice President Education Services [email protected] 1 2014
TACHA. All Rights Reserved
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Mark of Excellence 2014 TACHA. All rights reserved. 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. NACHA owns the copyright for the NACHA Operating
Rules & Guidelines 2 2014 TACHA. All Rights Reserved
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Telephone Banking Internet Banking Bill Pay Mobile P2P 3 2014
TACHA. All Rights Reserved
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Internet Banking Telephone Banking Bill Pay Mobile P2P 4 2014
TACHA. All Rights Reserved
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Bill Pay Bill Pay Mobile P2P Internet Banking Telephone Banking
5 2014 TACHA. All Rights Reserved
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Mobile Banking P2P Bill Pay Bill Pay Telephone Banking Internet
Banking 6 2014 TACHA. All Rights Reserved
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P2P Telephone Banking Mobile Banking Internet Banking Bill Pay
7 Here we are today! 2014 TACHA. All Rights Reserved
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The Person-to-Person Payment 8 2014 TACHA. All Rights
Reserved
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Receiver Originator ODFIRDFI Debit Originators Account Credit
Receivers Account ACH Operator ACH Network 13 2014 TACHA. All
Rights Reserved
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DEFINITIONS Introducing the Person-to-Person Payment 14 2014
TACHA. All Rights Reserved
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Person-to-Person Entry (P2P Entry) Credit entry initiated by or
on behalf of a holder of a consumer account that is intended for a
consumer account of a receiver P2P entry uses the Internet-
Initiated/Mobile Entry (WEB) Standard Entry Class Code 15 2014
TACHA. All Rights Reserved
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Customer Initiated Entry (CIE) Credit entry initiated by or on
behalf of the holder of a consumer account to the non-consumer
account of a receiver 16 2014 TACHA. All Rights Reserved
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Internet Initiated/Mobile Entry (WEB) Credit entry initiated by
or on behalf of the holder of a consumer account that is intended
for the consumer account of a receiver, regardless of whether the
authorization of such entry is communicated via the Internet or
wireless network 17 2014 TACHA. All Rights Reserved
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P2P AND NACHA OPERATING RULES 18 2014 TACHA. All Rights
Reserved
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Person-to-Person Rule Objectives Provides clarity and
consistency about how to apply the Rules to P2P Payments Allows
RDFIs to receive P2P transactions with standard formatting for use
in providing transaction information to their customers Enables
Originators and Third Party Service Providers to implement internal
processes and procedures in order to improve operations and
customer service, reduce costs, reduce risk and fraud, and minimize
exceptions and disputes 19 2014 TACHA. All Rights Reserved
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Person-to-Person Effective March 21, 2014 Approved: March 7,
2013 Defines P2P payment in NACHA Operating Rules Creates new
Credit WEB Entry specifically for P2P payments Clarifies how
Notifications of Change (NOCs) should be handled for P2P WEB
credits and for bill payment CIEs 20 2014 TACHA. All Rights
Reserved
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Company Name Field To identify P2P service provider In Company
Batch Header Record Field 3 and position 05-20 Alphameric 16
characters in length 21 2014 TACHA. All Rights Reserved
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Company Entry Description Descriptive statement for P2P type
payment Field 7 and position 54-63 Alphameric 10 characters in
length 22 2014 TACHA. All Rights Reserved
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Individual Identification Number Field Identifies Sender or
Originator WEB Entry Detail Field 7 and position 40-54 Alphameric
15 characters Required on statement & transaction reports 23
2014 TACHA. All Rights Reserved
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Payment Related Information Free form plain text option Addenda
Record Field 3 and position 04-83 80 characters Not required for
statement but consider value 24 2014 TACHA. All Rights
Reserved
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P2P Formatting Individual Name = Receivers name Who is
receiving the P2P entry? Individual ID = Originator/Senders name
Who sent the P2P entry? Company Name = P2P service provider Whose
assisted in sending the P2P entry? 25 2014 TACHA. All Rights
Reserved
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S or R Single or recurring Entry Detail Field 9 and position
77-78 Denoted like the WEB debit 26 Payment Type Code 2014 TACHA.
All Rights Reserved
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WEB Can Batch Together 27
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Periodic Statements For P2P Company Name is Service Provider,
not Originator RDFI must provide the Receiver with Originators
(senders) name Originator for WEB Credits is in Individual ID
Number RDFI Must provide contents of Individual ID Number field to
consumer only for WEB Credits Not if WEB Entry is a reversal of a
debit WEB Entry REVERSAL would appear in Company Entry Description
in Company Batch Header Record For P2P Company Name is Service
Provider, not Originator RDFI must provide the Receiver with
Originators (senders) name Originator for WEB Credits is in
Individual ID Number RDFI Must provide contents of Individual ID
Number field to consumer only for WEB Credits Not if WEB Entry is a
reversal of a debit WEB Entry REVERSAL would appear in Company
Entry Description in Company Batch Header Record 28 2014 TACHA. All
Rights Reserved
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P2P WEB Credit WEB Debits Credit WEB - No Origination Agreement
Credit WEB - No Receiver Authorization Credit WEB - Additional ODFI
Warranties do not apply Debit WEB Entries are subject to risk
management rule provisions that apply as a prerequisite to
Origination WEB Audit requirement does not apply to WEB Credits P2P
Debits consumer to consumer Consumers originating debits to
Consumers require Originator Agreement and all applicable Rules 29
2014 TACHA. All Rights Reserved
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Impact to ODFIs Statement requirements Posting date Dollar
amount Payee name Entry description Account type and Account number
Amount of charges for services related to entry Balances in account
at beginning and end of statement period Address and telephone
number for inquiries or notice of errors Education with staff and
customers Conversation with vendors This is same information RDFI
provides to its consumer Receivers of ACH entries 30 2014 TACHA.
All Rights Reserved
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P2P Notifications of Change Clarifies the treatment of NOCs for
CIEs and credit WEB Entries When CIE or WEB credit NOC is received
by the ODFI, the ODFI required to make the changes, or provide the
bill payment or P2P provider with the necessary information Within
two Banking Days of the Settlement Date of the NOC or corrected NOC
Regular NOC time frames apply 31 2014 TACHA. All Rights
Reserved
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WHAT IS YOUR FINANCIAL INSTITUTION DOING TODAY? 32 2014 TACHA.
All Rights Reserved
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Bill Payment vs. P2P Portal 33
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Whos the ODFI of the P2P entries? 34 TPSP Your financial
institution ODFI 2014 TACHA. All Rights Reserved
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35 I need to send money to my daughters account at another
financial institution every month. Would you please send this to my
account at my other financial institution?
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THINGS FOR FINANCIAL INSTITUTIONS TO CONSIDER 36 2014 TACHA.
All Rights Reserved
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Take Into Consideration.. Can consumer customers send debit
and/or credit entries through online banking? If so, can this also
be done through mobile banking? Who does the financial institution
use as a Third-Party Service Provider for the P2P product? 37 2014
TACHA. All Rights Reserved
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Take Into Consideration.. Does the financial institution have
any restrictions in place for P2P payments? Are there eligibility
requirements? Customer ratings Length of relationship Overdrafts
Returns 38 2014 TACHA. All Rights Reserved
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Take Into Consideration.. Are there limits in place related to
P2P payments? Are limits the same for all consumers? What
authentication is in place for consumers initiating P2P payments
through online banking? What are password requirements? What locked
out procedures are in place? 39 2014 TACHA. All Rights
Reserved
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Take Into Consideration.. How are online account changes
monitored and verified? Address changed Phone number changed Email
address changed Alert notifications changed 40 2014 TACHA. All
Rights Reserved
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Take Into Consideration..... Employee access Does the financial
institution minimize and monitor the number of personnel with
access to systems that support ACH services? Does the financial
institution minimize and segregate ACH staff and limit access to
various maintenance and transaction support functions Editing users
Editing account numbers Editing transaction limit Editing user
profiles 41 2014 TACHA. All Rights Reserved
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In Conclusion.. Financial institutions are welcoming new
products and services NACHA Operating Rules provides framework for
P2P payments Financial institution has to manage the risk related
to the new products and services 42 2014 TACHA. All Rights
Reserved
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Contact Information 1000 NorthChase Drive Suite 201
Goodlettsville, TN 37072 Office: (615) 859-4188 Cell: (615)
636-8695 Fax: (615) 859-3719 Website: www.tacha.org 2014 TACHA. All
Rights Reserved 43