Special Considerations for Payments Destined to
United States

Pre-Reporting and Availability of Funds

Pre-Reporting or Availability of Funds is not available on consumer credit payments destined to the United States identified as Standard Entry Class Code of IAT. Credit payments destined to Business identified as IAT are not eligible for Pre-Reporting.

The Pre-Reporting or Availability of Funds does not apply to debit payments.

Scheduled Exchanges

Currently there is one exchange per day with the clearing agent in the United States. If you submit your input credit file by the time indicated this will ensure that your customers are credited on the due date of the payments. There is no guarantee that your customers will have access to their funds via Automated Banking Machines (ATM) the morning of the due date of the payment.

Files received earlier will allow you more time to add, change, delete or correct payments.

Effective September 18, 2009: New International ACH Entries (IAT) required for payments Destined to the U.S.

NACHA, (the National Automated Clearing House Association) which is responsible for developing the operating rules and business practices for the Automated Clearing House (ACH) Network and for electronic payments in the United States, has approved an International ACH rule change that takes effect on September 18, 2009. The rule redefines International ACH entries to incorporate payment activities that are identified as cross-border entries.

This means that for all transactions you originate that are destined to the U.S. you will need to collect, store and pass new fields of information.

The U.S. Office of Foreign Asset and Control (OFAC) gave NACHA the opportunity to self-govern by updating the Originator and Originating bank obligations and requirements under OFAC. NACHA took seriously the message that OFAC would step in if NACHA did not take steps to address this gap in the network and now that with the rule approval, all financial institutions and corporations which will have to be compliant by September 18, 2009.

The rules and format replaces the existing cross border rules with a single Standard Entry Class (SEC) code, IAT (International ACH Transaction). The IAT format will carry mandatory addenda records to satisfy the Bank Secrecy Act's "Travel Rule" information:

• Name and physical address of the Originator;
• Name and physical address of the Receiver ("Beneficiary");
• Account number of the Receiver;
• Identity of the Receiver's bank;
• Correspondent Bank(s) name, Bank ID number and Bank Branch Country Code;
• Reason for the payment.

The IAT format can also accommodate two optional addenda records of remittance information. The expanded definition of what qualifies as an International ACH entry and the expanded format fields have been added so that ACH transactions can be monitored for signs of terrorism or crime.