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#1221902 - 07/24/09 01:54 PM IATs
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Couple questions. We're a community bank and act as receivers. The only origination we provide is for payroll for key customers. We were wondering how we can identify a situation where one of the origination customers may "slip in" an IAT transactions? Would it kick out automatically, say, because the trans. would be missing some of the travel rule info?

Did you revise all your ACH agreements? Did NACHA provide suggested language to include in the agreements?

Thanks!

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#1221995 - 07/24/09 02:47 PM Re: IATs Trees
AnnRoy Offline
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AnnRoy
Joined: Jun 2002
Posts: 771
South
Trees:

From what I read, it's the ODFI's responsibility to educate the originators about the IAT transactions. I don't think an originator will be able to "slip" an IAT in their file.

As for revising our ACH agreements, our ACH Officer hasn't made a decision on thaty lately and NACHA is not planning to provide any suggested language.
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#1222034 - 07/24/09 03:20 PM Re: IATs AnnRoy
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,844
Pulling people out of the ditc...
well, since IAT is a new SEC code, your system should be able to scan and flag it. I don't see a need to create a new ACH agreement unless the current agreement you have spells out specifically which SEC codes you allow a customer to originate. However, most agreements are now SEC code neutral, meaning they don't list each code out.
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#1222102 - 07/24/09 04:08 PM Re: IATs HappyGilmore
Trees Offline
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Joined: Apr 2005
Posts: 4,013
That's assuming they use the new SEC code. I know I am way out there with this questions, but....my peeps are parenoid. So, assume Bus. A sends in their payroll and, somehow, one of their employees is a trucker living in Canada. So, in originating the payroll, if I understand you, unless Bus. A uses the SEC code for IAT, the trans. will reject as it will not be coded correctly. That takes care of that scenario. Now lets assume Bus. A did some homework, uses the correct IAT code and, unbeknown to us, includes the trans along with the other payroll credits....I'm just trying to understand how we can catch these types of hiccups. Comments welcome!

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#1226080 - 08/01/09 03:13 PM Re: IATs Trees
ComplyWithMeToo Offline
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Joined: Feb 2007
Posts: 225
Has anyone come up with language to inform customers?

My BSA department wants to notifiy both consumer clients and business clients that funds from ACH deposits may be temporarily suspended for verification against OFAC lists.

We found under OFAC Q&As that this would be okay to do. I just don't know HOW to do it!

Anyone doing this? Any suggested language would be great.

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#1228133 - 08/06/09 02:20 PM Re: IATs Trees
pacar Offline
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Joined: Jul 2007
Posts: 320
Trees -
Do you have the ablility to "turn on" and "turn off" certain types of SEC's for your ACH Originators? Our core system allows us to designate which SEC's the originator can use.

As for a seperate agreement, we are just going to be drafting an addendum - much like we did for TEL's - that outlines the rules associated with IAT's. It's unlikely that we will have any origination issues (like you, we are a small community bank) but we need to be ready.

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#1229811 - 08/07/09 08:50 PM Re: IATs pacar
kiemo Offline
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kiemo
Joined: Jan 2009
Posts: 267
MidUS
We are in process of revising ACH policy and procedures to include the fact that altho required to receive IAT, we will not send any IAT for our originators. We are a small (conservative) community bank also and currently allow only send PPD standard entry class code items for our originators. Thanks for the remind about need for originator agreements update.

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