national check payments certification image exchange: rules and agreements – part i copyright©...

National Check Payments Certification

Image Exchange: Rules and Agreements – Part I

Copyright© 2014 by the Electronic Check Clearing House Organization

NCP 2015 Exam CycleCore Training Series

Session 5

NOTICESThis training course may provide an introduction to or summary of various aspects of check payments and the legal and rules framework for check image exchange. Responsibility for compliance with image exchange rules, and/or the legal, operational and regulatory requirements applicable to check image exchange, remains at all times with the financial institution participating in check image exchange and/or the individual or company using a check image exchange service.

This presentation and the information contained herein is not intended as legal or compliance advice or recommendation to any person or company. This document could include technical inaccuracies or typographical errors and individual users are responsible for verifying any information found in this presentation and related “live” webinar or webinar playback. Financial institutions should consult with their legal counsel regarding legal and operational requirements applicable to any check image exchange program they may offer or in which they participate.

These program training materials may not be reproduced or published, in whole or in part, without the express permission of ECCHO.

Copyright© 2014 by the Electronic Check Clearing House Organization(Certain contributed content subject to third party copyrights)

National Check Payments Certification 2

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Session Overview

• Rules and Agreements• ECCHO Rules – Key provisions• Warranties and Indemnification Summary

–Forward and Return


Rules and Agreements

Industry Rule Sets

• Exchanging Check Images with Federal Reserve–Need agreement with the Federal Reserve

• Image exchanges between DFIs and FRB’s–Federal Reserve Image Exchange Rules - Operating

Circular 3 (OC3)–Covers exchange of check images through Federal

Reserve Banks– Incorporates Reg J

Federal Reserve Board regulation regarding check processing

–Does not cover non-Fed image exchangesNational Check Payments Certification 6

7National Check Payments Certification

Industry Rule Sets

• Exchanging Check Images in Private Sector Channels–Need private sector rules and agreements

• Private Sector Image Exchange Rules–ECCHO Rules

Electronic Check Clearing House OrgoClearing house rules under UCCoRules considered agreement under UCC and Reg CCoOnly apply to members of ECCHO that agree to exchange

images under rulesLicensed by The Clearing House (TCH)

–Bi-lateral or Multi-lateral Agreements

Bank ABOFD

(Member)

Bank BCorrespondent

(Member)

Bank C Paying Bank

(Member)

CommonWarranties

IMAGE &

MICR Data

IMAGE &

MICR Data

All Banks are Members of Same Clearing House and Using Common Rules

Common Set of Rules

CommonWarranties


Bank ABOFD

(Non-Member)

Bank BCorrespondent

(Member)

Bank C Paying Bank

(Member)

CommonWarranties

IMAGE &

MICR Data

IMAGE &

MICR Data

Potential Rules Mismatch

Exchange Not Covered By Common Clearing House Rules

Common Exchange Under Clearinghouse Rules

Correspondent Agreement

Possible Mismatch of Agreement(s) and Common Rules• Correspondent

Agreement may not fully address all legal issues for the collection/presentment of check images with non-member


Rules and Agreements

• Banking Practices Agreement (BPA)–Specifically state “agreement to exchange

under the rules”–BPA also includes:

Operational logisticsDetails of rules provisions that may be varied by

agreement• BPA may be incorporated with other

network or clearing house rules


Banking Practice Agreements• General Considerations

– Agreement to use ECCHO Rules for Image Exchange and Electronic/Image Return Processing

– Start dates for both Forward and Return exchanges– Image file formats and related companion document– Routing number identification (for File Header Records)– Eligible R/Ts– Location for delivery of presentment notices and images– Presentment Notice Timing – With image or before/after image– Image Ledger Cut-off Time– Deadlines

Receipt Deadlines for Presentment Notice and ImageAcknowledgement deadlines

– Exchange Network– Settlement Process– Communication facility– Settlement Process or Organization– Adjustments Process or Organization– Provisions that can be varied by ECCHO rules

• May Include Other provisions Not ListedNational Check Payments Certification 11

Other Agreements

• Common Rules Generally Cover Bank-to-Bank Exchanges–ECCHO Rules are for member exchanges

Members must be financial institutions• Agreements Needed to Cover Customer-to-Bank

Exchanges–Contract between bank and their customer–Examples:

Deposit account agreementsRemote Deposit Capture (RDC) agreementsOther image-enabled products/services agreement



Other Agreements• Agreement for Remote Deposit Capture (RDC)

– Bank’s contract with their customerAddress the liabilities and responsibilities with respect to items

deposited remotely– Review key points in FFIEC Guidance for RDC risk management

in electronic environment (Jan. 14, 2009)– Guidance focuses on RDC deployed at a customer location

Principles of RDC risk management discussed are applicable to various forms of remote deposit operations including:o Internal deployment via ATM, Branch, Cash Vaulto Customer RDC include mobile banking consumer

• Agreement with Third Party Provider– Address liabilities and responsibilities for creating and/or

sending check images and substitute checks

ECCHO Rules Provisions

Sending Bank/ BOFD

Returnee Member

ICL

Receiving Bank/Sending Bank / Presenting Bank

Returnee Member / Returning Member

Receiving Bank / Paying Bank

Returning Member

Agreements

DEPOSITING CUSTOMER

Deposit Check

DRAWEE CUSTOMER

Switch Archive

ICL

TRUNCATES / STORES CHECKS

Sub Check

Process Overview

Image CashLetter

Image CashLetter


General Provisions

1. Clearinghouse rules under UCC and Reg CC– Rules are an “agreement” under UCC and Reg CC

2. Members follow applicable industry standards– Not reject a file based on rejection of individual item(s)

3. Status of electronic image is – “Check” under Reg CC and “Item” under UCC

Similar to language in Reg J as referenced in OC3National Check Payments Certification 16

Within Sending Bank Rule Considerations4. Eligible Items – Sections III(A) & XIX(C) & XV & XVII

a. Check under Reg CCb. Full MICR line

– Partial by permitted by agreement- As-read MICR- RNA (Routing Number and Amount)

c. Agreement for exchange (BPA)– Participation in imaging program is voluntary

- Agreement not required to be writtend. May send Imperfect Image Itemse. Rules agreement to transmit Savings Bonds (SB)

Do not meet requirements for eligibility Subject to regulations and guidelines of U.S.

Treasury May be commingled with other images in same

image cash letter file

Forward Presentment

Sending Bank/ BOFD

Deposit Check

Agreements

DEPOSITING CUSTOMER

TRUNCATES/STORES CHECKS


Within Sending BankRule Considerations5. Repair – Section III(C)

a. Routing number and amount (default)b. Full field – Sending Bank responsible for amount

of item and expenses if exercise ordinary carec. Other repair based on law and agreement

6. Data Security – Section IXd. Warrants it has established appropriate

safeguards to protect data (admin/technical/physical safeguards)

e. Notification of security breachf. Liable for cost of customer notification

7. Third Party Agent – Section IVa. May use Third Party b. Bank remains responsible

Forward Presentment

Sending Bank/ BOFD

Deposit Check

Agreements

DEPOSITING CUSTOMER



Rule Considerations8. Indorsement – Section XIX(E)

a. Must endorse check or imageb. Electronic indorsements allowedc. Require at least one electronic indorsementd. If BOFD must apply BOFD indorsement

9. Image Return – Section XIX(J)a. Return in accordance with Section XX and

hierarchy10. Retention – Section XIX(K)

a. Sending Bank determines11. Retrieval Requests – Section XIX(K)

b. Sending Bank respond to request with commercially reasonable effort

12. Confidentiality – Section Xc. Cannot disclose customer information with

some exceptions– Both consumer and business customers

Sending Bank/ BOFD

Deposit Check

Agreements

DEPOSITING CUSTOMER


Forward PresentmentWithin Sending Bank

(continued)


Rule Considerations13. Warranties – Section XIX(L) & XV(I) & XVII(G)

a. Complies with requirements of rulesb. Image accurately reflects checkc. Presentment notice accurately describes checkd. Image is acceptable copye. Image corresponds to item described in

presentment noticef. Image contains all information required by

standardsg. No duplicate presentmenth. Member or Customer not incur loss due to

Imperfect Imagei. Sending Bank (first must be Depositary Bank)

warrants item not forged, unauthorized or counterfeit (Section XIX(N) – “Rule 9”)

14. Indemnification – Section XIX(L)j. Full indemnificationk. Comparative negligence defense permitted

Forward PresentmentWithin Sending Bank

(continued)

Sending Bank/ BOFD

Deposit Check

Agreements

DEPOSITING CUSTOMER



0145 B0000029545B

Related Physical Check

Presentment Notice

0145 B0000029545B

Electronic Image

=Warranty Section XIX (L)(2)

=Warranty Section XIX (L)(3)

=

War

ranty

Sec

tion X

IX (L

)(5)

Chain of Warranties


Within Receiving Bank / Sending Bank Rule Considerations

15. Identification of appropriate deadlines for Presentment Notice and Electronic Image – Section XIX(D) (BPA)

16. Identification of Location – Section XIX(G) (BPA)17. Managing Electronic Connection – Section XIX(G)

a. Sending bank responsible for transmission or other transport

b. Receiving Bank responsible to manage its connection

Forward Presentment

ICL

Receiving Bank / Sending Bank /

Presenting Bank

ICL

Agreements

Switch Archive


Within Receiving Bank / Sending Bank Rule Considerations

18. Receipt – Section XIX(G)a. Not received if receiving bank can’t process fileb. Not reject entire file due to a number of bad

itemsc. Must notify sending bank if unprocessabled. If Receiving bank cannot process due to its

problems may be viewed as failure to exercise ordinary care

19. Acknowledgements - Section XIX(G)a. As receiving bank required to send

acknowledgmentb. As sending bank for images that are “made

available” required to send acknowledgment20. TIFF Reformatting – Section V(B)

a. Receiving bank may reformat non compliant TIFF and not responsible for losses

Forward Presentment

ICL


Presenting Bank

ICL

Agreements

Switch Archive


Rule Considerations21. Retention/Recreation – Section XIX(G)

a. Receiving Bank may request resend of entire file (Up to 4 days after settlement)• Sending Bank has two days to respond• Sending Bank relieved of liability for resend

b. Receiving Bank may request resend portion of file• No timeframe or requirement to respond• Sending Bank relieved of liability for resend

Forward PresentmentWithin Receiving Bank /

Sending Bank(continued)

ICL


Presenting Bank

ICL

Agreements

Switch Archive


Rule Considerations22. Indorsement - Section XIX(E)

a. Must include subsequent indorsement(s)b. Must include indorsement(s) received to ensure

complete chain23. Exchange Arrangements - Section XVI

c. If no other agreement exists, “backstop” rule allows Receiving Bank/Returnee Member agreement to apply

24. Savings Bond – Act with ordinary care as correspondent bank – Section XVII(A)

25. Receiving Bank Warranties – Section XIX(M)d. Complies with requirements of rules

26. Indemnification – Section XIX(M)e. Full indemnificationf. Comparative negligence defense permitted

Forward PresentmentWithin Receiving Bank /

Sending Bank(continued)

ICL


Presenting Bank

ICL

Agreements

Switch Archive


Rule Considerations27. Retention – Section XIX (K)

a. Copy for 7 years28. Presentment – Section XIX(H)

b. Image ledger cutoff time section XIX(A)b. Occurs when presentment notice and image

are received or made availablec. Banks cannot agree to extend time of

presentment


Agreements

Forward PresentmentWithin Paying Bank


Check 21 Provisions Rule Considerations29. Recourse to Prior Collecting or Returning Bank –

Section XIX(Q)a. Recourse to prior bank for Check 21 liabilityb. Expedited Recredit Claim for banks mirrors

Check 2130. Member creating Substitute Check from Imperfect

Image solely responsible for loss – Section XV(H)

Receiving Bank/Paying Bank

DRAWER CUSTOMER

Agreements

Sub Check

Forward Presentment


Sending Bank/ BOFD

Returnee Member

ICL




Returning Member

Agreements

DEPOSITING CUSTOMER

Deposit Check

DRAWEE CUSTOMER

Switch Archive

ICL


Sub Check

Returns Process Overview

Image CashLetter

Image CashLetter


Rule Considerations1. Rules clearinghouse rules under UCC 4-103 and Reg CC 229.37 – Section II(B)2. Members shall use applicable industry standards – Section V(A)

a. Not reject file using rejection for individual items3. Status of Electronic/Image Return - Section XX(E)

a. Electronic/Image Return is check under Reg CC and Item under UCCb. Rules agreement under UCC and Reg CC

Returns


Within Returning Member /Paying Bank

Rule Considerations4. Eligible Items – Sections III(A) & XX(C) & XV

a. Originally Received Item is Check under Reg CCb. Full MICR line, if Originally Received Item is paper

- Partial by agreementc. May return:

- Modified MICR line to correct error or omission; or

- MICR line as receivedd. Agreement – without agreement not required to

accept returne. May send Imperfect Image Items

- As-read MICR- Flag item; PIL allowed

5. Data Security – Section IXa. Same rule as Forward

6. Third Party Agent – Section IVa. Same rule as Forward

Returns

* Required by applicable law

Returning Member/Paying

Bank

Agreements

DRAWER CUSTOMER


Rule Considerations7. Indication on Return – Section XX(D)

a. It is a return*b. Reason for return*

8. Multiple Return Reason – Section XX(D)a. Not required to indicate all return reasons

9. Indorsement – Section XX(D)a. Must include indorsement *b. Recommend maintain indorsements from

prior exchanges10. Electronic Message Return data requirements (no

image) – Section XX(D)a. Identification of data requirements, some

required by Reg CC* for NIL

* Note: Paying Bank Not Required to Indorse (under Reg CC)

Within Returning Member /Paying Bank (cont.)

Returns


Bank

Agreements

DRAWER CUSTOMER



Rule Considerations11. Return Routing – Section XX(D) (see Hierarchy)

a. Return to BOFD in electronic indorsement, if none then

b. Return to BOFD on back of Image, if none thenc. Return to oldest (first appearing) electronic

Indorsement, if none then d. Return to source

12. Transmission of Return – Section XX(F)13. Timeliness of Return – Section XX(F)*


Returns


Bank

Agreements

DRAWER CUSTOMER

* Note: Paying Bank Not Required to Indorse (under Reg CC)



Bank identified in Type 26 Record(If more than one newest (last appearing))

Bank Identified on Back of Image

Bank Identified in Oldest (first appearing) Type 28

If Type 26 Record is Present

If Type 26 Record is not Present

If Back of Image Unreadable or

Missing

If no Type 28 Records Are

PresentActual Source of Item

Return Routing Hierarchy


Rule Considerations14. Electronic Message Return Section XX(G)

a. Maintain copy for seven (7) yearsb. Guarantees all prior and missing indorsements

15. Confidentiality – Section Xa. Same rule as Forward

16. Warranties – Section XX(J) & XV(I)a. Complies with requirements of rulesb. Electronic/image return accurately corresponds to

originally received Item being returnedc. Image return is acceptable copyd. No duplicate presentmente. Member or Customer not incur loss due to

Imperfect Image17. Indemnification – Section XX(J)

f. Full indemnificationg. Comparative negligence


Returns



Bank

Agreements

DRAWER CUSTOMER


Within Returnee Member / Returning Member Rule Considerations

18. Identification of appropriate deadlines – Section XX(F)19. Identification of Location – Section XX(F)20. Managing Electronic Connection – Section XX(F)

a. Returning Member responsible for transmission or transport

b. Responsible to manage its connection21. If not BOFD – Section XX(F)

c. Transmit or provide Electronic/Image Return to BOFD or other Member*

22. Receipt – Section XX(F)d. Same rule as forward Section XIX(G)

23. Retention/Recreation – Section XX(G)e. Same rule as forward Section XIX(G)

24. May reject/return Savings Bond for any reason - Section XVII(F)

Agreements

ICL


ICL

Switch Archive


Returns


Within Returnee Member / Returning Member (cont.) Rule Considerations

25. NOI – return to BOFD – Section XIX(F)26. Exchange Arrangements - Section XVI

a. Same rule as forward27. Warranties – Section XX(K)

b. Complies with requirements of rulesc. If not BOFD, Return within applicable

deadlines*28. Indemnification – Section XX(K)

d. Full indemnificatione. Comparative negligence

Returns


Agreements

ICL


ICL

Switch Archive


Within Returnee Member/BOFD Rule Considerations29. Return warranty or other claim through

Adjustment process – Section XX(F)30. If have Check indicate – Section XX(F)

a. It is return;b. Reason for return;c. Return check

31. If BOFDd. Provide Image Return or related information

to its customer*32. Allowance for two representments – Section XX(I)

a. Recommend maintaining previous indorsements and return reason codes (Commentary)

Returnee Member/BOFD

DEPOSITING CUSTOMER

Agreements

Sub Check

Returns



Check 21 Provisions Rule Considerations33. Recourse to Returning Member – Section XX(L)

a. Recourse to prior bank for Check 21 liabilityb. Expedited Recredit Claim for banks mirrors

Check 2134. Member creating Substitute Check from

Imperfect Image solely responsible for loss – Section XV(H)

Returns

Returnee Member/BOFD

DEPOSITING CUSTOMER

Agreements

Sub Check


Sending Bank/ BOFD

Returnee Member

ICL




Returning Member

Agreements

DEPOSITING CUSTOMER

Deposit Check

DRAWEE CUSTOMER

Switch Archive

ICL


Sub Check

Returns Process Summary

Image CashLetter

Image CashLetter

Summary/Review



ECCHO Rules

• Remotely Created Check Warranty Claim Process [Section XIX(N)]–Generally referred to as “Rule 8”

Developed in local paper clearing houses–Definition of RCC / warranty in Reg CC with July 2006

amendmentMoves liability from Paying bank to BOFD

–ECCHO Rules set forth process for Paying Bank to make an Unauthorized RCC warranty claimClaim must be made via returns process

o To location BOFD receives returnsDetailed process and related timing outlined in RulesSample forms included in exhibit to ECCHO Rules


ECCHO Rules• Remotely Created Check Warranty Claim Process

(continued)–ECCHO Rules Section XIX(N) updated Dec-2014:

Removed requirements for:o Paying Bank’s customer to file written statement within 60 days of

statement date; ando Paying Bank to file claim back to BOFD within 15 days

–Current Rule provisions: Timing:

o Paying Bank’s customer must complete/sign/deliver a written statement under penalty of perjury (WSUPP); and

o Paying Bank must deliver claim to BOFD within 90 calendar days after presentment of item in question

BOFD may not disclaimo Cannot disclaim timely Rule 8 claim on basis BOFD or their customer has

evidence item was authorized by the Paying Bank’s customer (the payor)

ECCHO Rules• Unauthorized RCC – Warranty claim in Adjustment

Matrix– Allow “Rule 8” claim through adjustments– Mirror Fed process and timing– BOFD can not disclaim RCC adjustment claim by stating

Paying Bank’s customer authorized RCC• If Paying Bank determines it has claim under Reg CC

warranty:– Paying Bank can make claim to BOFD via return channel –

Section XIX(N) – Paying Bank may use adjustment process for RCC warranty

claim – Section XII – Paying Bank may make claim outside ECCHO rules processNational Check Payments Certification 42

ECCHO Rules• Forged and Counterfeit Check Warranties

– Generally referred to as “Rule 9”– Sending Bank (that is Depositary Bank) warrants:

Signature of purported drawer is not forged or otherwise unauthorized, and/or

Related Physical Check is not counterfeit– Participation is default in Rules

Opt-out permitted unless clearing arrangement does not allowIf opt-out is cancelled (default back to participation under the

rules), cannot elect to opt-out again for 6 months– Similar process as RCC warranty claim

Claim made through return process but is not a returnNo adjustment facility in rules

– Cannot send through the FedNational Check Payments Certification 43

“Rule 9” Claim – Section XIX (O)

Banks are all ECCHO Members

Statement

Depositing Customer

IMAGEPaperCopy

SubCheck

or or

Warranty Claim made directly to Depositary BankWithin 15 Business Days of receipt of WSUPP - Image, Paper Copy (front/back) or Sub Check

Paying Bank

IMAGE IMAGEDepositedCheck

BOFD

Bank X

BOFD Requests Copy of WSUPPWithin 15 Business Days

of receipt of claim

Available $ to Cover Warranty Claim?Charge Customer

-or-Disclaim – Back to

Paying Bank

ECCHO Rules

44

Rule 9 – Claim Process Timing



Non-Imageable Items

• Categories of checks that cannot be processed through image include:–Ineligible items–Non-imageable items

• Non-imageable and/or ineligible checks can be costly exceptions

• ECCHO rule added in 2009 –Address imperfect images

ECCHO Rules• Imperfect Image

– Permits member to send Imperfect Image for forward exchange or return

• Imperfect Images are Exceptions– Electronic image/image return containing image that:

Does not conform to industry standardsDoes not pass quality edits for exchange

– Must be identified / flagged– Some rules apply while others will not– Can be returned or adjusted– Can create a substitute check

Creating bank fully responsible– Warrant receiving member and their customer will not incur

loss as a result of receiptNational Check Payments Certification 47

ECCHO Rules

• Image Perfect Images – Examples–Image of Item in Carrier

May qualify as Imperfect Image ItemIf image of the carrier containing the item is

unreadable or otherwise does not meet applicable industry standards

–Photo-in-Lieu (PILs)PILs not required to have electronic flag

oPrinted legend on the photocopy meets this requirement


ECCHO Rules• Adjustment Rules – Approved Oct-2009

– For adjustment claim to be made for an item exchanged between ECCHO members, the type of adjustment must be:Listed on the adjustment matrix, andItem must be an image

• Ongoing changes to Rules and Matrix– Based on new information and to better align to industry

practices and providers• For more information:

– Fed and ECCHO adjustments rules and adjustment types will be discussed more fully in the upcoming “Exceptions – Returns and Adjustments” session


Summary• Warranties/indemnities in image world come from different

sources– Laws, rules and agreements

• To determine which law or rule applies, is item:– Original physical item– Substitute check (IRD)– Image

• For images, determine presentment/clearing channel– Through Fed (Reg J and OC3 apply)– Through clearinghouse (clearinghouse rules (i.e., ECCHO))– Directly from bank to bank (clearinghouse rules and agreements apply)

• Generally, warranties start at first bank that deals with substitute check or check image – Note: Remote deposit customer (RDC)

Warranties/obligations set by contract (agreements)National Check Payments Certification 50

Warranty & Indemnification• Warranties/Indemnification Review

– Understanding and comparing the warranties and related indemnification regarding certain exchanged itemsECCHO Rules / UCC / Reg CC / OC3 / Reg J

– ECCHO Rules incorporate by reference provisions of UCC and Reg CCSection XIX (F) – Forward exchangeSection XX (E) – Return

• P.R.E.P. Guide – Warranties Tables– Training guide exhibits provide outline of warranties and related

indemnification for:UCC, Reg CC, Reg J, OC 3 and ECCHO Rules

– Exhibits 5 and 6: Forward Exchange Warranties & Indemnification– Exhibits 7 and 8: Return Warranties & Indemnification


Questions

????? ?National Check Payments Certification 52

Recommended Resources

• ECCHO website: www.eccho.org/rules

• CheckImage Central website – White paper on role of rules in image exchange: www.checkimagecentral.org/pdf/RoleOfPrivateSecRulesAndFRSRules.pdf

• Regulation CC (12 CFR – Part 229):www.ecfr.gov • NCP P.R.E.P. Guide

– Available to all exam candidates upon registration


http://www.eccho.org/rules

http://www.checkimagecentral.org/pdf/RoleOfPrivateSecRulesAndFRSRules.pdf

http://www.checkimagecentral.org/pdf/RoleOfPrivateSecRulesAndFRSRules.pdf

http://www.ecfr.gov/

Thank You!

Image Exchange: Rules and Agreements – Part I

Electronic Check Clearing House Organization3710 Rawlins Street; Suite 1075

Dallas, Texas 75219

NOTICEThis NCPC Program document contains copyrighted materials of its publisher.

These program training materials may not be reproduced or published, in whole or in part, without the express permission of ECCHO.

Ellen Heffner, NCPDirector of Education

[email protected]

national check payments certification image exchange: rules and agreements – part i copyright©...

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