Update to OFAC FAQs Regarding Cuba Travel-Related Transactions

The U.S. Treasury’s Office of Foreign Assets Control (OFAC) has updated its Frequently Asked Questions regarding Cuba travel-related transactions by U.S. financial institutions.  Question #52 has been added: Is a financial institution required to independently verify that an individual’s travel is authorized when processing Cuba travel-related transactions? No. A financial institution may rely on U.S. travelers to provide their certifications … Read More

Requirements for Consumer Authorizations for Preauthorized Electronic Fund Transfers

The CFPB has posted an article and announced its issuance of Bulletin 2015-06 on automatic debits. The article explains to consumers the way an auto debit to a financial institution account works and the protections for the account owner, and provides links to action letter templates consumers can use to invoke those protections. The Bulletin alerts companies that they must … Read More

ACH Unauthorized Entry Fee

The Rule is intended to improve ACH Network quality by reducing the incidence of ACH debits that are returned as unauthorized. Under this Rule, an ODFI will pay a fee to the RDFI for each ACH debit that is returned as unauthorized (return reason codes R05 reserved, R07 authorization revoked by customer, R10 customer advises not authorized; ineligible, notice not … Read More

NACHA Third-Party Sender Registration Proposed Rule

The proposed rule would apply to Third-Party Senders that are the ODFI’s direct customers, as well as those other Third-Party Senders that are direct customers of the first Third-Party Sender, otherwise known as “nested” Third-Party Senders (The rule would also apply regardless of whether the ODFI allows the Third-Party Sender Direct Access to an ACH Operator. In the case of … Read More

Same-day ACH Rule (NACHA)

The NACHA rule change will enable ACH Originators that desire same-day processing the option to send same-day ACH transactions to accounts at any receiving financial institution (RDFI). The Rule includes a “Same-Day Fee” on each same-day ACH transaction so that RDFIs would recover, on average, their costs for enabling and supporting same-day ACH. The Rule will enable the option for … Read More