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Ask Mary: Did I Miss Anything Due to COVID-19?!

Dear Mary, 2020 has been a rollercoaster – can you fill me in on what I may have missed while my world was turned upside down?

Let’s face it – nothing about 2020 has been normal. And, understandably, you may have missed a change or two while trying to navigate these trying times. So, here’s a recap of major payments changes, things to have on your radar and virtual educational opportunities at EPCOR.

Some important changes:

  • March 20, 2020: The dollar limit for each Same Day ACH transaction increased from $25,000 to $100,000.
  • April 1, 2020: Updates were made to the ACH Return Codes R10 and R11. R10 continues to be used for unauthorized transactions, while R11 can now be used for transactions that are not processed in accordance with the Terms of the Authorization. Financial Institutions should ensure their Written Statement of Unauthorized Debit is updated with the new requirements.
  • July 1, 2020: Regulation CC Subpart B was amended based on the requirements under the Dodd-Frank Wall Street Reform Act. The Funds Availability dollar limit for deposits transitioned from $200 to $225. Additionally, exception hold funds availability requirements were also increased from $5,000 to $5,525.
  • July 21, 2020: Regulation E Subpart B, also known as the International Remittance Transfer Rules, increased the safe harbor for financial institutions who don’t send consumer-initiated transfers during their normal course of business. Under the original safe harbor, financial institutions that sent less than 100 consumer-initiated transfers within a calendar year were not required to follow many of the requirements under the rule. With the safe harbor set to expire, the Consumer Financial Protection Bureau updated the regulation to include normal course of business within the definition of a remittance transfer. Within that definition, the number of transactions associated with normal course of business was changed from 100 to 500 transactions within a calendar year.

Things to keep on your radar:

  • July 1, 2020: ACH Contact Registry – ODFIs and RDFIs are required to register a contact person or department contact for their ACH Operations area and a contact person from their Risk Management/Fraud area. Financial Institutions have until October 30, 2020 to complete the registration process. The information should be updated annually.
  • March 19, 2021: The Federal Reserve is adding a Third Processing window for Same Day ACH transactions. Other areas impacted by this change include an extension of the National Settlement Service and Fedwire Funds Services.

Same Excellent Education – Virtually Remixed!

Don’t let 2020 hinder you from staying on top of payments industry changes! All of EPCOR learning events are now virtual and we have something for a variety of functional areas and levels of expertise!

For a full list of our educational offerings, visit the online store.

As always, if you have any questions please don’t hesitate to reach out to Member Support via phone (800.500.0100), email (memserve@epcor.org) or chat with us on our website (epcor.org). And, don’t forget that your fellow EPCOR members on the Knowledge Community are a great resource as well. Happy learning!