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Payments Pulse

Payments Pulse
The Clearing House
Payments Pulse

Industry News & Resources

Reg CC Amendments Effective July 1st

Source: FRBServices.org

Final Rule - Remittance Transfers under the Electronic Fund Transfer Act (Reg E)

Source: CFPB

“Massive Fraud” Against State Unemployment Insurance Programs

Source: Krebs on Security

Paychex Releases HR Industry’s First Real-Time Payments Solution

Source: Paychex

Two New Nacha Requests for Comment

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.


We Get Questions...

Q and A
Q.)   What do we do if we notice a suspicious unemployment benefit via ACH credit posting to one of our account holders and it’s not in their name? In some cases there are multiple deposits to one account. Are we liable as an RDFI? What do we do with the funds?
A.)   As long as the entry posts automatically to a valid account, the RDFI is not liable (except for payments that are later subject to reclamation). If an entry is deemed suspicious or fraudulent, your next steps should be to notify your BSA Compliance Officer and follow your BSA/AML procedures. Financial institutions don’t have to make the funds immediately available as defined by Regulation CC, which allows for the funds to be held while an investigation is being conducted. If you, as the RDFI (or together with the account holder), decide the entry is to be returned, you should use the ACH return reason code that best fits the situation. If the account holder notices it and claims it’s not theirs, return it R23. Another return code that sends the best message for some of these transactions is the R17; keeping in mind “QUESTIONABLE” must be listed in the addenda of the return. Don’t forget the 2-day return timeframe for the R17 (RDFIs need to react fast). Another option would be the R03 since the name on the account doesn’t match the name on the transaction. We have spoken to Nacha, and you are encouraged to be timely, so the R17 works within the 2 day timeframe only. Since R23 doesn’t have a timeframe tied to it, this can be used if you are outside your R17 opportunity, even if the transaction was not brought to your attention by your account holder. And the R03 is also an option. In this particular wave of fraud, the ODFIs are likely not accepting R06, since you would want a Letter of Indemnification from them. Focus on the best return reason code; the use of R23, R17 and R03 will be your best line of defense.
We will continue to communicate with our payments industry partners and provide additional details, when available, via the Payments Pulse newsletter and TCHPA home page.

ACH Rules Product Survey

When we ask your opinion, we listen to your answers and react accordingly. A new survey, developed by Nacha and the Center for Payments (including TCHPA), asks members to provide answers to questions about your use and preferences relating to the ACH Rules products (book, online access, and digital app). This short, 9-question anonymous survey should take no more than 2-3 minutes to complete.
Each year TCHPA hosts a pre-production sale for the upcoming year’s Rules with significant discounts for those who order during the promotion window. This is the best time of year to order for your staff and ACH Origination customers, but we’d like to know what drives your decisions when choosing one product over another. For ODFIs, we want to hear about the steps you take to ensure your Originators have access to the Nacha Operating Rules & Guidelines.
Your responses will be helpful to our team when planning for ACH Rules pricing and order fulfillment in the future. Thank you in advance for sharing your opinions and feedback.

Payments Nerds

We’re proud to be payments nerds – we love sharing perspectives on all things payments. The Payments Nerds podcast features expert guests who explore the most important issues, topics and trends to consider in payments today. If you are a payments nerd too, or are a little bit curious about what’s going on the payments world, you’ll want to check out the Payments Nerds podcast from The Clearing House. The most recent episode is “Making Real-time Payments for Payroll with Paychex with Eric Wade” discussing the new real-time payroll product from Paychex using the RTP® network and its benefits. Now available with easy access on the TCH website.

Upcoming TCHPA Education
No charge for members!

June
4

BSA/AML Compliance Virtual Workshop
(Webinar)

June
18

Payments Systems Update

June
19

AAP/APRP Alliance Virtual Meeting

June
23

Check Pain Points and Common Questions

RDC All-in-One Resource Guide Now Available

New in 2020! This all-in-one resource provides sample procedures and documentation to help financial institutions effectively implement a Remote Deposit Capture program for consumers and companies. Don't spend your valuable time writing and creating documents! The RDC Resource includes everything you need to establish or enhance your RDC policies, procedures and risk management:
  • Legal Governance
  • Considerations for RDC Policy and Procedures
  • Sample RDC Risk Management Policy
  • Sample Annual Review Considerations
  • Sample RDC Check Destruction Tracking Log
  • RDC Customer Self-Audit and Customer/Merchant Audit Considerations
  • RDC Training Guide
$195 for Members – Order Now

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!

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