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Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

Take On Payments

February 6, 2017


ACH: No Trace Left Behind

In my payments research role, I believe that one problem with ACH is the lack of any definitive method for identifying a payment and any associated return, dishonored return, or contested-dishonored return using only the existing 15-digit trace number. Ideally, the trace number alone should facilitate the correct retrieval of payment or return details even if other payments contain duplicate payment details, such as for recurring payments.

This PDF file contains an image that outlines the complex web of relationships that can be used to trace back returns to the original payment. Without the benefit of a unique trace number, the identification of the original payment could involve using common data elements to minimize misidentifying the payment.

A unique trace number would offer the following advantages:

  • Unambiguously identify a specific payment
  • Facilitate tracking features similar to what is available from package delivery services such as transmittal, settlement and receipt date/time, and similar tracking of any associated return(s)
  • Enhance risk-monitoring capability
  • Simplify reconciliation and auditing
  • Flag or prevent a return from settling before its associated forward payment
  • Identify "orphan" returns sent across the public network when the original payment was sent privately between financial institutions (FI)
  • Link together forward and return payments for certain international payment applications that are not possible today

Under NACHA rules, the FI originating the payment assigns a unique 15-digit trace number; the trace number's uniqueness is necessary to differentiate each payment in the batch. Uniqueness is not mandated across payments in other batches in the same payments file. Consequently, a trace number could be repeated in multiple payment files on the same day or across many days—and, even more troublesome, within the same payments file. NACHA strives for uniqueness by mating the trace number with an associated batch number, transmission (file creation) date, and a file ID modifier. Unfortunately, any return of a payment only passes along the original trace number without the benefit of the mated data.

A possible solution that could overcome the current limitations of the trace number would be a one-time-use, ACH-operator-assigned, 15-character alphanumeric trace number. When the originating network operator receives a file, the operator would replace the FI trace number with a unique trace number that he or she would forward to the receiving FI. Any return sent back to the originating FI would have the unique operator trace number converted back to the original FI trace number. For convenience, a cross-reference file associating operator trace numbers with FI trace numbers could help facilitate non-network communication between originating and receiving banks.

Operators could guarantee uniqueness by allowing an operator trace number to contain digits and upper and lowercase letters. Expanding to a 62-character set results in over 3.5 trillion distinct values using the last seven characters of the trace number (the first eight characters are the originating FI's routing and transit number). Further requiring at least one non-numeric character allows differentiation with FI numeric-only trace numbers.

What are your views on the benefits and disadvantages of non-repeatable trace numbers?

Photo of Steven Cordray  By Steven Cordray, payments risk expert in the Retail Payments Risk  Forum at the Atlanta Fed

February 6, 2017 in ACH, payments | Permalink

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I like this idea. It would also make it extremely easy for an FI to research a transaction within their records by using the unique trace number. You are looking at around 20 billion transactions per year so the 3.5 trillion should easily cover the 6 year record retention requirement.

Posted by: David L Payne | February 7, 2017 at 06:58 AM

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January 9, 2017


The Year in Review

As we move into 2017, the Take on Payments team would like to share its perspectives of major payment-related events and issues that took place in the United States in 2016, in no particular order of importance.

Cybersecurity Moves to Forefront—While cyber protection is certainly not new, the increased frequency and sophistication of cyber threats in 2016 accelerated the need for financial services enterprises, businesses, and governmental agencies to step up their external and internal defenses with more staff and better protection and detection tools. The federal government released a Cybersecurity National Action Plan and established the Federal Chief Information Security Office position to oversee governmental agencies' management of cybersecurity and protection of critical infrastructure.

Same-Day ACH—Last September, NACHA's three-phase rules change took effect, mandating initially a credit-only same-day ACH service. It is uncertain this early whether NACHA will meet its expectations of same-day ACH garnering 1 percent of total ACH payment volume by October 2017. Anecdotally, we are hearing that some payments processors have been slow in supporting the service. Further clarity on the significance of same-day service will become evident with the addition of debit items in phase two, which takes effect this September.

Faster Payments—Maybe we're the only ones who see it this way, but in this country, "faster payments" looks like the Wild West—at least if you remember to say, "Howdy, pardner!" Word counts won't let us name or fully describe all of the various wagon trains racing for a faster payments land grab, but it seemed to start in October 2015 when The Clearing House announced it was teaming with FIS to deliver a real-time payment system for the United States. By March 2016, Jack Henry and Associates Inc. had joined the effort. Meanwhile, Early Warning completed its acquisition of clearXchange and announced a real-time offering in February. By August, this solution had been added to Fiserv's offerings. With Mastercard and Visa hovering around their own solutions and also attaching to any number of others, it seems like everybody is trying to make sure they don't get left behind.

Prepaid Card Account Rules—When it comes to compliance, "prepaid card" is now a misnomer based on the release of the Consumer Financial Protection Bureau's 2016 final ruling. The rule is access-device-agnostic, so the same requirements are applied to stored funds on a card, fob, or mobile phone app, to name a few. Prepaid accounts that are transactional and ready to use at a variety of merchants or ATMS, or for person-to-person, are now covered by Reg. E-Lite, and possibly Reg. Z, when overdraft or credit features apply. In industry speak, the rule applies to payroll cards, government benefit cards, PayPal-like accounts, and general-purpose reloadable cards—but not to gift cards, health or flexible savings accounts, corporate reimbursement cards, or disaster-relief-type accounts, for example.

Mobile Payments Move at Evolutionary, Not Revolutionary, Pace—While the Apple, Google, and Samsung Pay wallets continued to move forward with increasing financial institution and merchant participation, consumer usage remained anemic. With the retailer consortium wallet venture MCX going into hibernation, a number of major retailers announced or introduced closed-loop mobile wallet programs hoping to emulate the success of retailers such as Starbucks and Dunkin' Brands. The magic formula of payments, loyalty, and couponing interwoven into a single application remains elusive.

EMV Migration—The migration to chip cards and terminals in the United States continued with chip cards now representing approximately 70 percent of credit/debit cards in the United States. Merchant adoption of chip-enabled terminals stands just below 40 percent of the market. The ATM liability shift for Mastercard payment cards took effect October 21, with only an estimated 30 percent of non-FI-owned ATMs being EMV operational. Recognizing some of the unique challenges to the gasoline retailers, the brands pushed back the liability shift timetable for automated fuel dispensers three years, to October 2020. Chip card migration has clearly reduced counterfeit card fraud, but card-not-present (CNP) fraud has ballooned. Data for 2015 from the 2016 Federal Reserve Payments Study show card fraud by channel in the United States at 54 percent for in person and 46 percent for remote (or CNP). This is in contrast to comparable fraud data in other countries further along in EMV implementation, where remote fraud accounts for the majority of card fraud.

Distributed Ledger—Although venture capital funding in blockchain and distributed ledger startups significantly decreased in 2016 from 2015, interest remains high. Rather than investing in startups, financial institutions and established technology companies, such as IBM, shifted their funding focus to developing internal solutions and their technology focus from consumer-facing use cases such as Bitcoin to back-end clearing and settlement solutions and the execution of smart contracts.

Same Song, Same Verse—Some things just don't seem to change from year to year. Notifications of data breaches of financial institutions, businesses, and governmental agencies appear to have been as numerous as in previous years. The Fed's Consumer Payment Choices study continued to show that cash remains the most frequent payment method, especially for transactions under 10 dollars.

All of us at the Retail Payments Risk Forum wish all our Take On Payments readers a prosperous 2017.

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Mary Kepler
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Julius Weyman
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Doug King
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Dave Lott
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Jessica Washington
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Steven Cordray

 

January 9, 2017 in ACH, ATM fraud, cards, chip-and-pin, cybercrime, debit cards, emerging payments, EMV, fraud, mobile banking, mobile payments, P2P, prepaid, regulations | Permalink

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October 3, 2016


Looming Questions with the Rollout of NACHA's Mandated Same-Day ACH Rules Change

On September 23, phase 1 of NACHA's three-phase rules change took effect, mandating two same-day ACH clearing/settlement windows for credits only. The subsequent two phases add debit payments in 2017 followed in 2018 by receiving banks being obligated to make credit payments available to receivers by 5 p.m. on the settlement day.

Prior to this change, using legacy ACH, one had to wait one business day for payments to clear and settle. A payment cap of $25,000 along with a mandatory interbank fee of 5.2 cents are other noteworthy differences for same-day ACH items as compared to legacy ACH. For some, these are unwelcome limits and fees, and time will tell the extent to which they stifle (or not) the service's growth. As the Federal Reserve's Financial Services website notes, a further limitation is that the federal government will neither originate nor accept same-day payments at this time, although plans are under way for their eventual participation.

I and others in the forum have commented on various aspects of this long-awaited enhancement here, here, and here. Now is probably a good time to proffer some questions for future consideration in helping to measure the success of this new venture.

  • Will projections in the first 12 months of service match NACHA's expectations of same-day garnering one percent of total ACH payment volume? Furthermore, will volume trending point to NACHA achieving its projection of 1.4 billion same-day payments by 2027? Early numbers may be somewhat misleading if payment originators inadvertently send payments for same-day settlement that were intended to be settled the following business day.
  • Whatever volume is achieved, will the primary payment use cases identified by NACHA be the actual drivers of same-day volume?
    • Payroll for hourly workers, late and emergency payrolls
    • Business to-business invoice payments with remittance information between trading partners that are under the $25,000 cap
    • Expedited consumer bill payments using both ACH credits and debits for just-in-time and late payments
    • Account-to-account transfers among accounts owned by the same consumer
  • Given the 18-month full implementation, how will same-day ACH hold up against existing faster payment schemes that leverage such things as debit card networks that offer much faster payments or even new faster payment schemes that are not reliant on existing payment rails?
  • How much, if any, will payment fraud increase with the availability of faster ACH?
  • How will service usage be impeded, if at all, by originating banks passing along the cost of the interbank fee to their payment originators?
  • Will the somewhat complicated eligibility requirements of no support for federal government payments, deferred debit, service and delayed funds availability slow adoption?

Despite these questions, there is reason to be optimistic. This is a major step forward for same-day ACH. What are your views on how these questions will eventually resolve themselves?

Photo of Steven Cordray  By Steven Cordray, payments risk expert in the Retail Payments Risk  Forum at the Atlanta Fed

October 3, 2016 in ACH | Permalink

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August 22, 2016


As with Nuclear Disarmament, So with ACH: Trust, but Verify

During his remarks at the signing of a nuclear disarmament treaty with the U.S.S.R. in 1987, President Ronald Reagan drew upon the old Russian maxim, "Doveryai, no proveryai," or "Trust, but verify." As with disarmament, businesses and others that originate automated clearing house (ACH) payments should be offered some way to verify an account, something more than hope and a prayer that the payment recipient's routing/transit number and account number are correct and that the recipient is an owner of the account.

The lack of efficient account validation options is a common complaint against the ACH. Surveys that NACHA conducted in 2012 and 2015 attest that account validation, as judged by a majority of respondents, is ACH's chief improvement need. Failing to perform account validation creates different levels of risk, depending on the payment application, whether a credit is pushed or debit is pulled and whether it is a recurring or one-time payment.

On July 19, NACHA's Payments Innovation Alliance and Board Advisory Group released two papers reviewing and critiquing existing methods for verifying bank accounts by financial institutions and businesses. The papers also suggest that a remedy to the account validation problem may be in the offing.

In both papers, NACHA defined account validation as follows:

A service wherein a business or financial institution can validate the accuracy of the account information received from a consumer or business, and the ability of that account to receive electronic payments.

Following are the various methods that NACHA identifies—and that I've complemented with my own research—that are used today to validate accounts:

  • Manual validation—A consumer's check verifies the account and identification verifies the consumer's identity. Alternatively, the originator can call the recipient's bank to confirm account details, assuming the bank is willing to provide the information, though it is risky for the bank to share such information over the phone.
  • ACH validation, via a zero-dollar prenote verification payment—If the account number is incorrect, the recipient's bank responds within three business days, though this timeframe can be shortened by using same-day ACH. As the papers state, this is a "no news is good news" form of verification. NACHA is exploring opportunities to improve the prenote process beginning in late 2016.
  • Challenge deposit validation—Typically, two micro-deposits of random amounts are made to the recipient's account and subsequently verified by the accountholder to the payment originator. Even if the account is successfully verified, the originator may subsequently be unable to debit the account because that account blocks debit payments. To identify debit blocked accounts, some originators debit the bank account equal to the micro-deposits. This method is fraught with a high abandonment rate by the consumer due to the hassle of verifying the deposits. One large online originator says that about 30 percent of consumers selecting the deposit validation method fail to verify the payment amounts. This method can take from five to seven business days—though, as with prenoting, the process can be expedited by using same-day ACH.
  • Instant validation—The customer logs into his or her bank from the company's website to establish ownership of the account. The same online originator said that 25 percent of its customers selected this validation method over deposit validation. Many consumers hesitate to use this method because the use of a third party increases the chance their banking credentials will be compromised.
  • Validation services—Service providers with access to a large number of accounts, offer scoring services that simulate or predict the likelihood an account number is "good." Though improving, these service offerings are limited for non-financial institution originators.

A solution to the problem may be in store through the World Wide Web Consortium and others working to develop a standardized application programming interface, or API, for account validation. This would allow payment originators or their service providers restricted access to bank data to verify accounts using a universal, standardized process while protecting banking credentials. Let's hope that key stakeholders rally around this important initiative and push for a speedy implementation so that we carry through with a new maxim of "Trust, but truly verify."

Photo of Steven Cordray  By Steven Cordray, payments risk expert in the Retail Payments Risk  Forum at the Atlanta Fed

August 22, 2016 in ACH, authentication | Permalink

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May 23, 2016


What Would Happen If the Lights Went Out for a Long, Long Time?

In 1859, a massive geomagnetic solar storm known as the Carrington Event caused extensive damage to telegraph systems and other nascent electrical devices worldwide. Telegraph lines sparked and telegraph operators could send and receive messages without the use of electric batteries. The Northern Lights lit up the sky in all of North America. Though not widely reported, on July 23, 2012 a massive cloud of solar material similar in magnitude to the Carrington storm erupted off the sun's surface, radiating out at 7.5 million miles per hour. Fortunately the impact of the solar storm missed Earth by nine days because of the Earth's orbit position.

One report estimates that a Carrington-level storm today could result in power outages affecting as many as 20–40 million Americans for a duration ranging from 16 days to two years at an economic cost of up to 2.5 trillion dollars. A research paper in Space Weather estimated the odds of a Carrington-level storm at about 12 percent over the next 10 years. Early warning of such a storm is possible since satellites can detect impending storms and have the potential to provide a minimum one-day warning before it hits Earth.

So what would happen if the lights went out in much of the United States because of such a cataclysmic event? One could anticipate serious disruption of electronic payments such as ACH, cards, and wire transfers in the affected areas and beyond. What would one do to facilitate commerce in such an emergency? Well, cash and, to a lesser degree, checks could come to the fore. Use of checks would be problematic given the electronification of checks, high risk of fraud, and overdrawn accounts if banking systems are not up and running. Cash would have fewer problems if it were on hand to distribute to the affected population. Perhaps cash accompanied by ration books could be used to mitigate hoarding.

For a low-probability extreme-impact event that results in cash becoming the only way, among existing payment instruments, for commerce to take place, what contingency plans are in place to ensure that consumers and businesses can obtain cash? Since the contingency systems we have in place to handle a future Hurricane Katrina or Hurricane Sandy are likely not sufficient for an extreme event of nationwide scale, some of the issues that need to be resolved include:

  • How does one ensure that sufficient cash is on hand during an emergency?
  • How is cash going to be distributed and accounted for along the supply chain with ATMs and bank offices and their core systems inoperable due to no electricity?

Addressing these questions and others involves a monumental effort, and I don't have a ready answer. Fortunately, cash solves the problem for small-scale, low-value payments during a long-term power outage. That is, during the immediate, in-person exchange, it is an instrument that doesn't require electricity, communication networks, or computers.

This and other major calamities have always made me concerned about the push in some quarters for a full transition to electronic payments at the expense of payments less reliant on electricity and our communication networks. As an engineer by training, it is in my nature to wonder what can go awry if failsafe systems aren't in place when the unexpected happens.

With the possibility of a catastrophic event in our lifetime, would you rather have cash in hand or a card/mobile app? As for me, I'm going to the bank to cash out my accounts and then on to the hardware store to buy a gas-powered electric generator. Just kidding, though I think serious consideration and appreciation is needed for the contingency aspects of cash when things invariably go awry.

Photo of Steven Cordray  By Steven Cordray, payments risk expert in the Retail  Payments Risk  Forum at the Atlanta Fed

May 23, 2016 in ACH, cards, checks, payments | Permalink

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April 11, 2016


Combat Gear for Tax Season

Recently, a local newspaper reported on two ex-bankers who were sentenced for their roles in a two-year-long fraud scheme. These ex-bankers created fraudulent bank accounts, then generated more than 2,000 false tax returns totaling more than $2.8 million in fraudulent refunds. The IRS has plenty more stories of tax fraud to tell.

Currently, "file taxes" is number one on my to-do list, and maybe yours. Do you shiver considering the possibility a tax return in your name has already been filed by someone else? Criminals, organized or not, know they can earn a living by filing fake returns. Even a legitimate taxpayer who owes taxes can be a victim of identity theft tax (IDT) refund fraud, as defined by the Internal Revenue Service's (IRS) Security Summit. (Note: The Electronic Tax Administration Advisory Committee, which reports to Congress, calls IDT refund fraud stolen identity refund fraud, or SIRF).

Formed on March 19, 2015, the Security Summit joins the IRS, state departments of revenue, and members of the tax refund ecosystem to discuss ways to combat IDT refund fraud. The Summit currently has seven working groups, including one focused on refund authentication and fraud detection. We have blogged before on the importance of data analytics in detecting fraudulent filings; this working group is attempting to strengthen these data tools. The working group also laid out best practices for software providers in enhancing identity requirements and strengthening validation procedures. At the end of last year, Congress provided a big assist in these efforts by passing the Protecting Americans from Tax Hikes, or PATH, Act of 2015, which closes one of the biggest loopholes in the tax refund process by requiring employers to electronically file W-2 forms and 1099 forms with the IRS by January 31 of each year instead of March 31. This new requirement, which becomes effective in 2017, will allow federal and state taxing authorities to match returns with actual W-2s for the first time.

The Security Summit also has a Financial Services Working Group, which explores ways to prevent criminals from using stolen identification credentials to establish financial services products such as checking accounts and prepaid cards that would allow the criminal to access the proceeds of fraudulent returns. After all, fraud may not be realized until after processing the tax return. Refunds are distributed either by check or direct deposit via ACH, which can be sent to a prepaid account (card) or traditional bank account. The IRS can't determine which account type an ACH refund is destined for since routing number and account number aren't standardized by account type, nor is there a database of routing numbers to identify prepaid accounts. Some have suggested that knowing when it is a prepaid account could be helpful in risk rating the return before sending the refund. The Financial Services Working Group has developed a standard state ACH file-naming convention so that state tax refunds can be identified by the industry in order to apply enhanced fraud filtering. Suspicious state tax refund deposits can be detected based on amounts, name matching, account type, length of relationship, and volume of deposits or withdrawals. The new format standard will strengthen fraud control systems in that all tax refund deposits will be able to be further scrutinized.

The Security Summit has a total of seven working groups, and they have their work cut out for them. While I shiver to think I could be a victim to identity theft, I support the progressive efforts to stop this crime, especially in the pre-filing and pre-refund stages so the criminals can't see a reward for their efforts.

Photo of Jessica Trundley By Jessica J. Trundley, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

April 11, 2016 in ACH, consumer fraud, fraud, identity theft | Permalink

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April 4, 2016


Same-Day ACH: A Call to Action

As my colleague recently blogged, there were standing-room only crowds during four sessions related to same-day ACH at an annual conference sponsored by EastPay and the Atlanta Fed. I moderated two of the sessions, which focused on operational and product opportunities available to financial institutions (FIs) in supporting faster payments.

My suspicion is that attendance was so heavy because many FIs still have a lot to do to get ready for faster payments. I was already aware of the lack of readiness among some of the processors that these FIs rely on so heavily. During one session, only a few hands were raised among 60 attendees when they were asked if they had been contacted by their processor about preparing for the September 2016 rollout. Of course, engagement is best when it's a two-way street. On the other side of things I have heard that processor training sessions devoted to supporting same-day ACH have been poorly attended. Additionally, FI session attendees indicated that no efforts were under way to educate corporate account holders about the looming service changes to ACH.

If my suspicions are right, the current state of things is troubling; the window of time left to prepare for Phase 1 is shrinking. September is less than six short months away.

Not being ready has some potentially serious, but avoidable, consequences for FIs and their account holders. Here are a few of the risks:

  • The two same-day submittal windows, which narrows the time between payment submittal and settlement, added to Phase 1 offer potentially greater risk of funds being sent out fraudulently as a result of corporate account takeovers unless FIs put proper controls in place to mitigate this risk. The potential for harm may be somewhat diminished given the individual transaction cap of $25,000.
  • Since the identification method for same-day payments relies on the requested settlement date using the Effective Entry Date field, some FIs could end up being surprised to learn their credits have settled sooner than they intended. Originators that have not been careful in selecting the settlement date will experience this "surprise."
  • If corporate originators inadvertently send same-day payments, such a mistake could prove costly. This is because the 5.2 cent same-day interbank fee, paid by the originating bank to the receiving bank, will likely be passed along to the originator. A corporate originator mistakenly sending same-day credit payments to 10,000 employees could incur an additional $520 fee plus any other upcharge associated with sending same-day payments.
  • Taxpayers may expect that just-in-time payments or late payments to avoid additional penalties can be made using same-day ACH to the IRS. As my colleague noted in the post I mentioned above, such payments will not be supported in Phase 1. Therefore, it is critical that FIs educate their account holders about this limitation.
  • Unless controls are put in place by their processors, FIs may have difficulty stopping same-day service to corporate account holders they judge to be too risky for sending same-day payments, or when agreements have not been put in place allowing corporate participation.
  • Since next-day ACH is the earliest settlement generally available today, some processors preclude using today's date as a settlement date. Unless this restriction is removed, originators would not be able to send same-day payments when Phase 1 service becomes available.

The risks outlined above are just some of the reasons FIs and their processors will want to be sure they are prepared for the September 23 deadline. Failure to do so could damage account holder relationships. NACHA, the regional payments associations, and the ACH operators offer a wealth of information on same-day ACH that all parties need to avail themselves of.

By Steven Cordray, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

April 4, 2016 in ACH | Permalink

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March 14, 2016


Same-Day ACH: An NFAQ

The NFAQ—meaning "non-frequently asked question"—will come just a bit further down in this post. First, I need to say the Forum's prediction that same-day ACH would not be a huge hit this year may have been misunderstood. The prediction wasn't meant to say that the service wouldn't gain steam over time; it was more a comment about the type of lift the initiative could experience at the start. But if usage of same-day ACH even somewhat mirrors the level of enthusiasm and participation that attendees lavished on sessions that revolved around the topic at Information Interchange, an annual regional payments association conference sponsored by EastPay and the Atlanta Fed, same-day ACH could become a big hit.

The aforementioned annual payment conference featured four sessions related to same-day ACH. Attendance at each session was standing room only. Topics focused on everything from understanding and preparing for the change to promoting usage and enhancing payment services for customers of all types.

It was really good stuff, I must say, and I managed to squeeze in all but one of the sessions. In the last session, the moderator opened by asking the audience questions to test their knowledge of the rule change and to help panelists focus on what information might be most useful for informing and instructing attendees. The audience didn't miss a single question, which included a trick question about the dollar threshold for "IATs" or international transactions. (IATs aren't eligible, so there is no applicable dollar threshold related to these payment types.)

Perhaps the most important question of the day, which takes me to the NFAQ in the title, didn't get asked in the open sessions. However, a gentleman leaned over and asked me if U.S Treasury transactions were eligible. I didn't think so and told him that, but he pushed back and suddenly we were both unsure. So after a short back and forth with my colleagues, I pointed him to a definitive answer in the same-day FAQs on frbservices.org. It reads as follows:

Q: Will the federal government be participating in Same Day ACH at any phase of implementation?

A: At this time, the federal government will not be participating in phase 1 of the Same Day ACH implementation. Therefore, any entry originated from, or received by, the federal government will not be eligible for same day settlement and will continue to settle on a future date. Information regarding the federal government's participation in later implementation phases will be forthcoming.

I felt compelled to share this "NFAQ" because after asking others about their understanding of the matter, I found general awareness and understanding mixed, but largely incorrect. The distinction between federal government payments and other types of government payments (state government agency payments will be eligible for same-day ACH in phase 1) may be important and may not be as widely known as it should be.

By Julius Weyman, vice president, Retail Payments Risk Forum at the Atlanta Fed

March 14, 2016 in ACH | Permalink

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November 2, 2015


Will NACHA's Same-Day ACH Rules Change Be an Exception-Only Service, At Least in the Short Term?

In May 2015, the 40-plus voting members of NACHA contingently approved mandating the acceptance of domestic same-day ACH payments by receiving banks. The voting members approved a three-phase development lasting 18 months. The first phase, starting in September 2016, is limited to credit pushes, followed one year later by debit pulls in the second phase. All payments are subject to a $25,000 maximum. By the final phase in March 2018, receiving banks will be required to make credit payments available to the receiving account holder by 5 p.m. local time to the receiving bank. Funds availability in the earlier phases is by the receiving bank's end-of-processing day. The service offers both a morning and afternoon processing window. A same-day return-only service is offered at the end of the business day. Lastly, originating banks are obligated to pay a 5.2 cent fee for every payment to recover costs to receiving banks.

Last month, the Federal Reserve Board of Governors removed the contingent part of the above approval by allowing the participation of FedACH, which serves as an ACH operator on behalf of the Reserve Banks. Approval followed a review of comments submitted by the public, of which a preponderance of the responses was favorable to FedACH participating in the service.

This was not the first time NACHA tried to mandate same-day ACH. Back in August 2012, a ballot initiative to mandate acceptance failed to receive a supermajority required for passage. Failure was due to a variety of reasons, and it was difficult to discern one overriding reason.

I think that most observers would agree that the earlier rollout of the Fed's proprietary opt-in, same-day service in August 2010 and April 2013 set the groundwork for mandating same-day.

As with any collaborative organization like NACHA, compromises were needed to garner sufficient votes for passage. The compromises included:

  • Same-day payment eligibility rules change due to a multi-phase development cycle requiring one-and-half years to complete from start to finish.
  • Providing certainty to the receiver that funds availability will be expedited on the day of settlement as part of the final phase, rather than earlier, which only requires posting by the receiving bank's end-of-processing day. The bank's end-of-processing day can be as late as the morning of the following business day.
  • Delaying a debit service by one year after the rollout of the phase one credit service will, to the potential surprise of the payment originator, delay settlement of debits one business day later than would occur for credits.
  • Any payment amount over $25,000 will settle one business day later than the payment originator may have expected if the payment originator is not aware of the payment cap.

Given these compromises, what do you think financial institutions can do to accelerate broader adoption of same-day?

By Steven Cordray, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

November 2, 2015 in ACH, regulations, regulators | Permalink

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April 27, 2015


Not Seeing a Tree for the Forest

For this blog's title, I confess to having pineapple-upside-down-caked the common adage "missing the forest for the trees." The thing is, I want to point to a particularly nice tree in the same day ACH (automated clearinghouse) forest. By torturing the adage I hope to inspire folks to deviate from the basic, same day forest flyover and focus on one tree. It seems to me it has not gotten all the attention due.

Those advocating for same day ACH generally tout the increased functionality or the economic benefits of the latest proposal. Another oft-mentioned benefit of the proposed rule change is that it may provide a bridge from today's payments to those of the future. However, tucked into the lush same day ACH forest is a hard-to-find risk abatement species. Allow me to point out some of its features.

Settlement—By reducing the settlement window, same day ACH reduces credit risk associated with the network ecosystem—both in terms of the length of time counterparties are exposed to settlement risk and, potentially, the total amounts of settlement risk. For sure, financial institutions will have more flexibility to better manage these circumstances.

Operations—Same day ACH provides additional processing windows that result in risk reduction opportunities. Operations managers gain the means to load balance or smooth processing volumes and may also be able to ease the pressure on deadlines. The additional processing windows can be thought of as de facto contingency alternatives and seem likely to yield a corresponding increase in reliability and quality for the ACH.

Returns—Expedited settlement means expedited return handling. same day ACH would provide the opportunity for receiving banks to return same day payments on that same day. Moreover, because return requirements are tied to settlement, any same day payment that needs to be returned to an originating bank will be received one banking day earlier than would have occurred without same day settlement. NACHA points out that exceptions may be identified sooner and returned sooner, which means resolution for more problems may begin sooner. They have described this as "a 'win-win' for all parties." It's hard to argue the point.

If it passes, same day ACH will improve the risk posture of financial institutions, benefiting both ACH payers and payees. As spring continues to unfurl, perhaps some of you will get to stroll through the woods. If you come across a particularly handsome dogwood or perhaps an eastern redbud, be reminded that the same day ACH ballot will pop later this spring. I'm keeping my fingers crossed that the woodsmen don't get to clear cut the forest this time and we don't lose any of the nice trees.

Photo of Julius Weyman By Julius Weyman, vice president, Retail Payments Risk Forum at the Atlanta Fed


April 27, 2015 in ACH, risk management | Permalink

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