June 24, 2009
Question:
Is NACHA going to revise the sample ODFI-Originator agreement to include IAT?
Answer:
No, the sample ODFI-Originator agreement found on page OG 17 of the NACHA Rules is provided for illustrative purposes only and has never been revised to include specific SEC codes or applications. The ODFIs and their customer should consult with their own counsel and rely on their own business judgment in determining to what, if any, extent they wish to utilize the form in the NACHA Rules book.
June 16, 2009
Question:
If my payroll needs to be sent as IAT, could my employees’ availability be affected?
Answer:
Yes, for two reasons; 1) unlike PPD, there is no requirement that IAT credit entries that are made available to an RDFI by its ACH Operator by 5:00 p.m. on the banking day prior to the Settlement Date be made available to the Receiver at the opening of business on the Settlement Date. Cleared IAT entries must be available no later than the Settlement Date of the entry, but funds are not required to be available at opening of business, and 2) if the IAT transaction were found to be suspect during the OFAC review, the transaction must be held until the issue is resolved and the item is cleared or identified as an actual OFAC violation.
June 10, 2009
Question:
For inbound IAT transactions, which FI is identified in the 4th addenda record?
Answer:
As defined in the Rules, for an Inbound IAT entry, the Originating DFI Identification Field within the Fourth Addenda Record must contain the National Clearing System Number of the foreign Originating DFI. It would follow that all other information in this addenda record should also relate to the foreign Originating DFI. Information about the U.S. ODFI/Gateway Operator is located in field 16 of the IAT Company/Batch Header record.