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Payments Pulse - April 22nd Edition

Payments Pulse - April 22nd Edition

Payments Pulse
Payments Pulse, April 22, 2020
The Clearing House
Payments Pulse

Industry News & Resources
COVID Pandemic / Stimulus Payments

TCHPA Home Page / COVID-19 and Payments


Nacha COVID-19 Pandemic Page

Includes Answers to Frequently Asked Questions

Economic Impact Payment Status

Source: IRS

CARES Act Provides Assistance to Small Business

Source: U.S. Dept of Treasury

IRS Tool to Help Non-Filers Register for Stimulus Payments


CARES Act Economic Impact Payments Communications Tool Kit

Source: Early Warning Resources for FIs

Health & Human Services (HHS) Provider Relief Fund


State-by-State COVID-19 Tax Filing Extensions


Treasury Check Information System (TCIS)


U.S. Treasury Checks: What You Need to Know

ECCHO On-Demand Webinar – FREE

Other News and Resources:

ACH Rules Supplement #2-2020

Effective Dates of the Rule for Supplementing Data Security Requirements
Protected content. Follow these steps to view: Login> My Account > Members Only

ACH Rules Errata #1-2020

Correction to Editing Error Return Reason Codes
Protected content. Follow these steps to view: Login> My Account > Members Only

Top 50 ODFIs and RDFIs for 2019

Source: Nacha

ACH Network Growth Likely to Slow Due to Covid-19

Source: Nacha

Updates to BSA/AML Examination Manual

Source: FFIEC

2020 Written Statement Unauthorized Debit (WSUD)

Includes R11 Return Language
Protected content. Follow these steps to view: Login> My Account > Members Only
Note: TCHPA has been working to assemble COVID-19 news and guidance from our payments partners and industry regulators to share with members. To keep up with the continual flow of COVID-19 news released between Payments Pulse editions, please visit the TCHPA Home Page for information that could have an impact on financial institutions, companies and the payments industry in general.

To Post or Not to Post…
RDFI Best Practices for Stimulus Payments

Treasury has not provided official guidance for handling the various scenarios that RDFIs will encounter, but based on what we’re hearing, stimulus payments should be treated like tax refunds and allowed to post to valid account numbers in accordance with the ACH Rules. They are to be considered entitlements rather than benefit payments like social security, etc.
Exception items should be handled in the same manner. In some cases, FIs will need to make a business decision to post (based on name and a similar account number, for example) while other payments will be returned (i.e. account closed). If returned, Treasury will decide if they should issue a check instead. HOWEVER, FIs should remember that the goal of the stimulus payments is to get funds into the hands of those who need them most. If someone has to wait for a check, it could take weeks or months...
We will continue to communicate with Nacha, the Fed and other payments industry organizations to get answers and share them with our members. Please check the TCHPA home page, Nacha COVID-19 Pandemic Page and your Payments Pulse newsletter for current details.


We Get Questions...

Q and A
Q.)   Our member received a $2400 stimulus payment because they filed jointly on their taxes, but the husband died last year. Since we can’t return a partial payment, how should this be handled?
A.)   While Treasury has not publicly addressed this particular scenario, we have been told the IRS has screened the Economic Impact Payments for eligibility and because they are to be treated like tax refunds, they are not subject to reclamations. With this in mind, FIs should allow payments to post as presented. The same holds true for a single $1200 payment when the recipient is deceased but the account is open. If account is closed, it should be returned using that reason code.
Q.)   Will the IRS/Treasury economic impact payments be exempt from garnishment?
A.)   Stimulus payments may be subject to certain U.S. Treasury offset requirements prior to being sent to the RDFI (i.e., child support orders). The Green Book describes the formatting convention that the Treasury would use in the event that it determines the payments are to be exempt.
Q.)   We have an account holder who is a tax preparer and her clients have their IRS refunds directly deposited into her account so she can deduct her fee and send the remainder to the taxpayer. The tax preparer is now receiving stimulus payments for the same clients. How should these be handled?
A.)   RDFIs should allow the payments to post to valid account numbers and follow normal procedures for inquiries when a would-be recipient is claiming non-receipt. The tax preparer needs to work it out with the tax payer and not the RDFI, who should not provide payment details to the tax payer for privacy reasons. They should also suggest that their customer (the taxpayer) visit the Get My Payment portal to provide their account information to avoid a similar issue in the event of a second stimulus payment.
Have a question for TCHPA? Call 800-875-2242 (choose option 3) or email education.services@theclearinghouse.org.

Payments University: A Virtual Experience in 2020
May 13-14th

Concerns over the COVID-19 Pandemic and shelter-in-place orders for Michigan and Puerto Rico have forced TCHPA to change plans for the previously scheduled in-person Payments University events. To avoid cancelling altogether, we have decided to re-schedule this year’s University as a virtual event and present all topics via live webinars scheduled over the course of two days.
There are still a lot of great topics on the agenda, that will be of interest to those who are new to their payments career and seasoned professionals alike. And although we’ll lose some of the ‘togetherness’ of the face-to-face event, the virtual event is now available to our larger audience, including some who may not have been able to attend due to travel restrictions to the original locations.
Registration is now open and we invite you to join us for this first-ever virtual Payments University experience. Best of all, there’s still NO CHARGE for TCHPA members.

2020 Audit and Risk Resources Now Available

These products have been updated for 2020 and are now available for purchase in the TCHPA online Payments Store.
Audit Interactive Workbook
This interactive electronic document (in fillable PDF format) provides point-by-point instructions for completing the annual ACH Operations Audit required by the ACH Rules. The workbook captures auditor notes and automatically generates a management report which can include audit findings, exceptions and recommended action items.
Risk Assessment Resource
This interactive electronic document (in PDF form) provides instructions for completing the ACH Risk Assessment as required by the ACH Rules. It includes an overview of documents required, procedures and best practices for completing the risk assessment. The assessment includes areas to record documents reviewed and interviews conducted, as well as document comments, suggestions and identified findings. The ACH Risk Assessment Resource is designed for both financial institutions and Third Party Providers/Senders.

Upcoming TCHPA Education
No charge for members!

APRIL
21

Third-Party Sender: ACH Audit Requirements
(Webinar)

APRIL
20-22

Nacha’s Smarter Faster Payments 2020: Remote Connect
Significant savings for those who register via TCHPA

MAY
5

Third-Parties: Managing Them and the Associated Risks
(Webinar)

MAY
6

Corporate Essentials: Faster Payments
(Webinar)

MAY
13-14

Payments University: A Virtual Experience
(Webinar))

All TCHPA Education
(80+ live and recorded webinar topics currently available!)
This might be a great time to catch up on your payments training and earn continuing education credits.

Member Support

Remember, when you need support from The Clearing House Payments Authority (TCHPA), you can reach our Member Services staff directly by calling 800-875-2242 and choosing option 3, or by emailing education.services@theclearinghouse.org. Although our staff is working remotely due to the COVID-19 pandemic, we’re still available to provide the support you need in a timely manner!
For the quickest answers related to stimulus payment exceptions, don’t forget to check the TCHPA home page and Nacha’s COVID-19 Pandemic Page. Links to current information are being added to these pages as new details become available.

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