Newsletter
INSIDE THIS ISSUE
(Fall 2007)
Data Breach Notification for ODFIs
Effective September 28, 2007 NACHA’s Interim Policy on Data Breach Notification took effect.
This Policy requires ODFIs, their Originators and Third Party Service Providers to notify NACHA
when consumer-level ACH data has been compromised.
The policy requires:
Commercially reasonable procedures to store, transmit and destroy data such as account with
routing numbers and names with social security numbers
Systems to detect a data breach occurrence
Escalation procedures to appropriate internal management and notification to NACHA if a
breach has the potential compromised information will be misused
All financial institutions should become familiar with the new requirements.
For more information link here.
NACHA Passes International ACH Rules
On August 14, 2007, the NACHA voting membership approved an amendment to the Operating Rules which
will require all ACH international payments to be identified as International ACH Transactions using
a new Standard Entry Class (SEC) Code—IAT. The new Rule will also require IAT payments include specific
data elements defined by the Bank Secrecy Act’s (BSA) “Travel Rule.” This rule change will eliminate the
existing CBR & PBR SEC Codes on March 20, 2009.
Many current international payments enter the U.S. ACH Network through correspondent banking relationships.
Consequently, a number of international payments that should be CBR & PBR transactions are formatted as domestic
transactions, making it difficult to ensure compliance with U.S. law.
The proper identification of these payments and the inclusion of “Travel Rule” information (i.e., Originator
name, address, account number; Originator’s depository institution name and payment amount; Receiver name, address,
account number; and Receiver’s financial institution) will make it easier to comply with OFAC-sanctions.
Although we are still developing education materials associated with the rule changes, several issues are certain
to affect every participant in the ACH Network. First, the acceptance of these transactions is mandatory for every
participating RDFI. Second, BSA “Travel Rules” require a review of the “data elements” by each participant who handles
the transaction, this means OFAC screening of the ODFI and Originator by the RDFI.
For more information about this and other rule changes affecting the ACH network, be sure to attend NWCHA's New Rules
Recap seminars during the first quarter of 2008 (dates, times and locations to be determined).
NWCHA Member Services
In-House-ACH training
We will customize a training session for your Financial Institution and make certain that your staff
get the proper information to safely and correctly process ACH transactions. Modules for operations
and front-line staff can be customized to your needs
Professional Audit Consultation
We will come to your office and assist in completing the mandatory ACH Audit. More than that, we will
also review your policies and procedures to provide recommendations that will improve your operations.
Corporate Originator Training
Whether a veteran or novice Originator, a great way to ensure originating companies receive accurate
information is to have one of the ACH Professionals at NWCHA create a customized training session. We'll
come to your location and give Originators the information for successful direct deposit and direct payment
processing.
Call our office today for pricing and to schedule the NWCHA Member Services that fit your Electronic Payments
needs.
AAP Exam
You know you have what it takes to join the elite corps of Accredited ACH Professionals (AAP)! It's
time to consider taking the AAP Exam in 2008
The AAP designation singles you out as a valuable resource by publicly demonstrating your understanding
and mastery of the policies and requirements of today's fast-paced electronic payments industry.
To help you prepare for the exam NWCHA offers our members special seminar discounts for anyone registered
to take the exam. For more details, please call our office and ask for Jim.
Exams dates and locations are being determined for 2008 we will inform our membership when all details have been arranged.
CIE Tax Payments Delayed
The U.S. Financial Management Service (FMS) has requested a delay in the implementation of a NACHA Operating
Rules change which established a banking convention for CIE entries used in online consumer Federal Tax Payments.
At this time FMS will reject consumer payments with the new format.
NWCHA’s 2008 Education Calendar
I am in the early stages of creating NWCHA’s 2008 Education Calendar and I’m asking for your help. My goal
is to create a schedule that meets your needs, so please give me a call at 206/622-7846 or send an email with
your suggestions. Thanks in advance for your assistance. Jim Petkovits, Education & Training Manager Petkovits@nwcha.org
|
