Everything ACH

A TEL entry is a transaction for which the authorization is received, orally, over the telephone.  TEL should only be used for Business to Consumer transactions and can only be debits.  Single, one-time debits to be specific.

Authentication:  Unlike most ACH entries, TEL transactions require that the identification of the consumer be verified before the authorization piece takes place.*

 Authorization:  The authorization requirements are very specific for TEL transactions and yet the ACH Operating Rules also give you a workable option.  Here’s the deal:

 TEL authorizations require the following 6 pieces of information:

 Date of the authorization

Date on or after which the transaction will post

The consumer’s name

The amount

A telephone number that is available and answered during normal business hours

A statement by the Originator that the authorization will be used to originate an ACH Debit

And here’s the option.  The Originator gets to decide whether to record the conversation that includes the exchange of those 6 pieces of information, OR provide* a notice to the consumer detailing those 6 pieces of information. 

In addition to all of that, the Originator must state clearly during the telephone conversation that the consumer is authorizing an ACH debit entry to their account, express the terms of the authorization in a clear manner and the Receiver (Customer) must unambiguously express consent.  Silence is not express consent.

Before you can use TEL, there is one last thing you should understand.  A TEL entry can only be transmitted when 1) there is an existing relationship between the Originator and the consumer or 2) if there is not an existing relationship between the Originator and the consumer, then it is the consumer who initiated the telephone call to the Originator.

* Notes: 

The Originator must use a commercially reasonable procedure to verify the consumer’s Routing Number.

Provide does not mean that the notice must be received by the Receiver only that it must be sent.  Usually the postmark or time/date stamp of an e-mail is sufficient proof that notice was sent before the transaction posted to the consumer’s account.

Formatting requirement:  Originators must ensure that the name of the Receiver is included within each TEL entry.

Because TEL transactions are one-time debits, they cannot be returned as R07 – Authorization Revoked.

There is so much more I could probably tell you about TEL transactions, but that’s all the big stuff and some of the little stuff too.  All of that being said, stay tuned for POP next.

CCD – Corporate Credit or Debit

CCD should only be used for any Business to Business transactions* and can be either Debits or Credits. CCD can be used for either a single one-time transaction or recurring transactions and may be accompanied by one addenda record.

Authorization: The authorization requirements are much more lax for CCD transactions* than PPD transactions which we discussed in the last post. However, I like to use the PPD authorization requirements as a guide for a really good authorization.

Here’s what the ACH Operating Rules say though: “The Receiver has authorized the Originator to initiate the entry to the Receiver’s account. In the case of CBR, CCD, and CTX entries, the Receiver has an agreement with the Originator under which the Receiver has agreed to be bound by these rules as in effect from time to time.” Essentially, to me, this means that there must be an agreement. That’s it, there must be an agreement.

The reasoning is that we all assume that when there is an ACH Authorization between two businesses that 1) it will be part of a larger agreement and 2) lawyers (with the best interest of the Receiver) will be involved. The difference of course is the assumption that the typical consumer would not have that luxury and therefore requires additional protections.

Please note that I strongly advocate the incorporation of all or as many as possible PPD authorization requirements be used in any Business to Business authorization.

 * Notes:

I know that I said that CCD should only be used for Business to Business transactions; there is of course, one exception. In the event a company is reimbursing an employee for expenses, that transaction to their personal/consumer account should be labeled a CCD.

Just because the requirements for CCD transactions are less onerous than PPD does not mean you should start using CCD for all of your transactions hoping to reduce your requirements. It does not work that way. Sending a CCD transaction to a consumer account, inappropriately, is a violation of the ACH Operating Rules.

And as before, when you have designed the authorization to suit your needs, please, please, please, be sure to pass it by your compliance person or preferably, your legal counsel before you roll it out for general use and after any future changes.

Stay tuned next week for TEL. Ring, ring.