Mobile ACH Payments
ACH Participant Survey
September 1, 2009
Survey Responses Due by Friday, October 16, 2009
NACHA requests comment on a proposal to amend the NACHA Operating Rules entitled
“Mobile ACH Payments.” This proposal would adopt provisions to address mobile payments in
the Rules.
This proposal may have business and technology impacts that go beyond those typically
considered in a Request for Comment. NACHA specifically requests that interested parties
circulate this RFC and help obtain input from organizations and departments that may be
impacted, but that may not typically respond to RFCs. For financial institutions, this could be
from areas responsible for technology, retail and online banking, and legal.
Survey responses and other comments are due to NACHA by October 16, 2009.
NACHA Staff Contacts
Return completed surveys to:
Maribel Bondoc, Manager, Network Rules
Fax (703) 787-0996
E-mail: [email protected]
Questions:
Julie Hedlund, Senior Director, Network Rules
Phone (703) 561-1100
E-mail: [email protected]
Michael Herd, Managing Director, Network Rules
Phone (703) 561-3924
E-mail: [email protected]
Section I - Respondent Information
Name:
Title:
Organization:
Phone:
E-mail:
Mobile ACH Payments,
ACH Participant Survey, 9/1/09, Page 2
Please indicate your organization’s role(s) in the ACH Network:
ODFI
RDFI
ACH Operator
Originator
Receiver
Other
Regional Payments Association
Government
Third-Party Service Provider
Software Vendor
Industry Association
Would your organization be willing to be contacted in order to provide more information on the
topics included within this survey?
Yes
No
Financial Institution Respondents – Please Complete
Asset Size
____ less than $250 million
____ $1 - $100 billion
Annual ACH origination volume
# entries
Annual ACH received volume
# entries
____ $250 million - $1 billion
____ greater than $100 billion
$
$
What areas of your organization provided input for the responses to this survey?
___ Operations
Wholesale/Corporate Banking/Treasury Management
___ Retail/Online Banking
___ Product management
___ Customer Service
___ Sales
___ Information technology/software
___ Legal
___ Other: ________________
______
Corporate Originators and Receivers – Please Complete
Annual ACH origination volume:
Annual ACH received volume:
# entries
# entries
$
$
Third Party Service Providers and Software Vendors – Please Complete
Which parties to ACH payments do you serve?
Originators
ODFIs
RDFIs
Mobile ACH Payments,
ACH Participant Survey, 9/1/09, Page 3
Section II – General Concept
1.
Does your organization agree that the NACHA Operating Rules should address mobile
ACH payments?1
Yes
No
Don’t Know
Specify why or why not:
____________
Section III – Short-Term Approach
2.
NACHA’s short-term approach in this proposal attempts to address the potential risks of
mobile ACH payments while avoiding the establishment of unnecessary barriers to their
use. Does your organization support this short-term approach?
Yes
No
Don’t Know
Specify why or why not:
3.
Does your organization believe that this proposal achieves a reasonable balance?
Yes
No
Don’t Know
Specify why or why not:
4.
Does your organization agree with the short-term approach to apply the WEB SEC Code
and associated rules to consumer ACH debits authorized or initiated via a wireless
network?
Yes
No
Don’t Know
The use of the term “mobile” in this RFC pertains to payments made with a mobile device such as a smart phone,
cell phone, and/or PDA where the payment information is transmitted via a wireless network as defined in this Rules
proposal. This RFC often uses the term mobile instead of wireless since mobile is the common industry vernacular
used to describe both the devices and the payment channel.
1
Mobile ACH Payments,
ACH Participant Survey, 9/1/09, Page 4
Specify why or why not:
5.
Does your organization believe the Originator Obligations2 for WEB entries are adequate
to address risks associated with mobile payments?
Yes
No
Don’t Know
Specify why or why not:
Section IV - Long-Term Approach
6.
NACHA’s long-term approach is to assess the impact of mobile ACH debits on the
Network and participants, identify any unique characteristics and risks, and evaluate the
need for either a unique SEC Code or other method to identify and track mobile
payments. Does your organization support this long-term approach?
Yes
No
Don’t Know
Specify why or why not:
7.
Does your organization believe that mobile ACH debits should eventually use a unique
SEC code?
Yes
No
Don’t Know
Specify why or why not:
If no, are there other methods to identify and track mobile payments volume that you
support?
Yes
2
No
Don’t Know
The Originator Obligations for WEB are to 1) Verify the Identity of the Receiver; 2) Deploy a Fraudulent
Transaction Detection System; 3) Verify the RTN; and 4) Conduct an Annual Security Audit. See NACHA
Operating Rules Section 3.10.
Mobile ACH Payments,
ACH Participant Survey, 9/1/09, Page 5
Please specify:
Section V – Other Issues
8.
Given that SMS/text messaging does not include native encryption, does your
organization agree that banking information necessary to initiate an ACH payment should
not be transmitted via a text message?
Yes
No
Don’t Know
Specify why or why not:
9.
Should the Rules require Originators to authenticate Receivers when they initiate or
acknowledge a payment instruction via a text message, even if no banking information is
transmitted via the text message?
Yes
No
Don’t Know
Specify why or why not:
10.
The Rules generally provide that the method of enrollment or authorization governs the
use of SEC codes. NACHA is proposing, however, that the WEB SEC code should be
used for mobile ACH payments even when the payment is initiated via a wireless
network, regardless of how the consumer enrolled or authorized the payment. Would
your organization support changing the requirement for existing WEB entries so that if
the debit is initiated via the Internet it should be coded as a WEB entry, regardless of how
the original authorization was obtained?
Yes
Specify why or why not:
No
Don’t Know
Mobile ACH Payments,
ACH Participant Survey, 9/1/09, Page 6
11.
Should the Rules address the storage of ACH information on the mobile devices
themselves?
Yes
No
Don’t Know
Specify why or why not:
12.
Are there other rule provisions that should be considered related to mobile payments?
Yes
No
Don’t Know
Specify why or why not:
Section VI – ODFIs
13.
Does your institution have Originators that are originating mobile payments over the
ACH Network?
Yes
No
Don’t Know
If yes, for what uses (e.g., bill payments, purchases, transfers)?
If yes, which SEC Code(s) are being used?
If no, do you have plans to do so?
Yes
14.
No
Don’t Know
Does your institution allow customers to initiate payments through mobile access to
online banking?
Yes
No
Don’t Know
Mobile ACH Payments,
ACH Participant Survey, 9/1/09, Page 7
If yes, by which methods?
Mobile web browser
Smart phone application
SMS/text message
Other
If yes, for what uses (e.g., bill payments, purchases, transfers)?
If no, do you have plans to do so?
Yes
No
Don’t Know
Section VII – Originators
15.
Does your organization originate mobile payments over the ACH Network?
Yes
No
Don’t Know
If yes, for what uses (e.g., bill payments, purchases, transfers)?
If yes, which SEC Code(s) are you using?
If yes, how and where are you providing the authorization disclosures?
If no, do you plan to in the near future?
Yes
No
Don’t Know
Section VIII - Impacts
16.
What benefits does your organization believe would be derived from this proposal?
17.
Does your organization have any concerns about or foresee any negative effects/risks
related to this proposal?
Mobile ACH Payments,
ACH Participant Survey, 9/1/09, Page 8
18.
Would there be a substantial operational impact to your organization associated with this
proposal?
Yes
No
Don’t Know
If yes, please specify:
19.
Would this proposal require changes to ACH software for your organization?
Yes
No
Don’t Know
If yes, please specify:
If yes, how extensive would the changes to your ACH software required by this proposal
be for your organization?
Extensive
_____
Moderate ______
Minimal
Provide an estimate of the costs involved: ______________
20.
Would there be changes needed to other software systems?
Yes
No
Don’t Know
If yes, please specify:
.
21.
Would implementing this proposal have a financial impact on your organization?
Positive
Specify why:
_____
Negative
Don’t Know
Mobile ACH Payments,
ACH Participant Survey, 9/1/09, Page 9
Provide an estimated financial impact:
Positive
_____ Under $10,000
_____ $10,000 to $100,000
_____ $100,000 to $500,000
_____ $500,000 to $1 M
_____ Over $1 M
Negative
_____ Under $10,000
_____ $10,000 to $100,000
_____ $100,000 to $500,000
_____ $500,000 to $1 M
_____ Over $1 M
Section IX - Proposed Implementation Date
Amendments to the NACHA Operating Rules may be implemented up to four times each year in
March, June, September, and December. Amendments with software changes may be
implemented in March and September.
22.
Does your organization support the proposed implementation date for this proposal of
December 17, 2010?
Yes
No
Don’t Know
Specify why:
If no, what implementation date do you believe would be more appropriate?
September 2010
March 2011
Other (please specify)
Section X – Other General Questions
23.
Are there any sections of the proposal that your organization believes should be balloted
separately?
Yes
Specify why:
No
Don’t Know
Mobile ACH Payments,
ACH Participant Survey, 9/1/09, Page 10
24.
Please identify any other specific issues that have not been addressed elsewhere in this
ACH Participant Survey (feel free to attach additional pages):