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“I would recommend EPCOR’sView our competitive pricing in the EPCOR Knowledge Community.Contact Audit@epcor.org to schedule your service.ACH Audit Services to any financialinstitution that is looking for a highlevel of expertise in the ACH Rulesand ACH payment system.”—Amber Mollaun, United Community BankEPCOR Audit ServicesIts All In the Details! 5 Payments System ExpertsMore than 100 Years of BankingExperienceAll Accredited ACH ProfessionalsNational Check ProfessionalsMore than 1,000 Audits & RiskAssessments Conducted Examiner Acknowledgment for ThoroughReportingDetailed Reports & Clear Explanationsof FindingsActionable Guidance & Education forImprovementsCompetitive Rates First time RDFI ACH Rules Compliance Audits Starting at 760! ODFI ACH Rules Compliance Audits Starting at 1,500! Third-Party Sender Audit and Risk Assesments ACH & RDC risk assessmentsLarry Matteson, AAP, CCM Jennifer Kline,AAP, NCPVice President of RiskManagementDirector, Audit ServicesAmy Donaghue, AAPSenior Manager, AuditServicesTricia Longo, AAP, NCPManager, Audit ServicesDanielle James, AAP, NCPManager, Audit Services8 2018 EPCOR Member Benefits & Services Catalog

The Inside Scoop:Auditor Findingspage 3Participate in our monthly Explore EPCORcontests to win 100*.*Restrictions apply. Visit the EPCOR homepage for contest details.Volume 2Just What Do ConsumersNeed to “Know BeforeThey Owe”?page 4EPCOR Website—Explore everything EPCOR has tooffer at www.epcor.org including award and scholarshipopportunities, available learning events, Audit andAdvisory Services and more!News You Can Use—This electronic newsletter informsyou of timely payment systems news, upcomingeducational offerings and member benefit programs.Choose to receive the e-newsletter weekly and/ormonthly, depending on your personal preference. NewsYou Can Use is also archived in the EPCOR All-MemberCommunity library of the Knowledge Community.EPCOR Bulletins—Critical, time-sensitiveinformation is sent on an as needed basis to theprimary contact at your financial institutionor company and other appropriate contacts asdetermined by the subject matter. All EPCOR Bulletinsare archived in the EPCOR All-Member Communitylibrary of the Knowledge Community.EPCOR Fraud Alerts—As soon as we know, you knowabout the criminal activities and/or fraudulent attacksaffecting the industry. Fraud Alerts are sent to theprimary contact and other appropriate contacts at yourfinancial institution or company and are also archivedin the EPCOR All-Member Community library of theKnowledge Community.Inside Origination—This periodic, electronic newslettercontains articles written from an a business accountholder's perspective that financial institutions canco-brand and share with ACH origination clients andall business account holders. Inside Origination is alsoarchived in the EPCOR All-Member Community libraryof the Knowledge Community.AskMaryHistorically, non-response to NOCs(Notifications of Change) has been anongoing issue in the ACH Networkand represented over 80% of the Rulesviolations submitted last year. At times,especially if you are an RDFI dealing withthe frustration, it can seem that an NOCmight be an acronym for “No One Cares.”NOVEMBER 2017Before addressing an ODFI’s andOriginator’s compliance obligationsrelated to receiving an NOC, let’s firstoverview the Rules Enforcement process,as potential fines related to non-responseto NOCs begin at 1,000.1.Payments Post—This quarterly printed newsletteris mailed to the primary contact at EPCOR memberorganizations, providing important payment systemsinformation and news in conjunction with the weeklyNews You Can Use e-newsletter. Payments Post is alsoarchived in the EPCOR All-Member Community libraryof the Knowledge Community.2018 EPCOR Member Benefits & Services Catalog 9Hear Ye:Regulation CCAmendmentsAre Finally Hereby Marcy Cauthon, AAP, NCP, Director,Payments & On-Demand Educationof Possible ACH Rules Violationform, along with documentationThe Federal Reserve Board (Board) hassupporting the claim.amended check collection and returnEach Report is evaluated byrequirements under Regulation CCNACHA. A Notice of Possible ACH (Availability of Funds and Collection ofRules Violation will be sent for aChecks) to facilitate the banking industry’sfirst-time infraction explaining the ongoing transition to a fully-electronicsited Rules violation and possibility check collection and return process. Thethat fines may be imposed if theamendments will take effect on July 1, 2018.violation is not corrected.The financial institution mustHere’s a summary of the Final Amendmentsrespond to the Notice within 10to Check Collection and Returnbanking days of receipt and eitherRequirements:(1) acknowledge the violation and Paper and electronic checks must beintent to correct the problem byreturned to the Bank of First Deposita specified date, or (2) provide ano later than 2 p.m. (previously 4 p.m.)statement, along with supportingon the second business day followingdocumentation, of why thethe banking day on which the checkinstitution doesn’t believe a Ruleswas presented to the paying bank.infraction occurred. The amended rule applies a notice ofIf NACHA receives a completenon-payment requirement to electronicand timely response,checks as well as paper checks, andno additional actionincreases the dollar threshold for whichwill be taken unlessnotice of non-payment is required to(1) NACHA believes 5,000. The amended rule also affectsthe timeframe forthe delivery time for the notice.resolution is excessive, Electronic checks are brought withinor (2) NACHA receivesthe coverage of Regulation CC. Theyan additional Ruleswill be treated the same as paper checksviolation report. In thesefor all purposes unless otherwise noted.On October24, theSenatewillvoted 51-50 to repeal the CFPB’s rule to ban class action waivers in consumer arbitrationsituations,NACHA The amended rule creates new2.3.Financial institutions may reportan alleged violation of the Rulesto NACHA within 90 days ofthe occurrence by completingand submitting a signed Report4.Senate Passes Resolution toRepeal CFPB Arbitration Rule,Signaling Rule’s Likely DemiseOVERVIEWagreements(the MARY“Arbitrationor the “Rule”). This marksthe firstmajorsee ASKon pageRule”3see REGCC onpage 4policy blow for the CFPB—an agency stillcontrolled by an Obama-era holdover—since President Trump entered office.By way of background, this pastsummer, the CFPB released a final ruleprohibiting a wide range of consumerfinancial services companies fromblocking consumer class actions byway of binding arbitration agreements.Although the Rule would not haveprohibited arbitration agreementsaltogether, many companies felt thatthe increased exposure to class actionlitigation would make arbitrationprograms economically untenable. TheRule would have also required coveredcompanies to provide informationon individual arbitration awards tothe CFPB for publication in a publicdatabase (redacting consumers’ privatefinancial information).Washington Watch—This electronic newsletter providesexecutive-level insights into governmental and regulatoryactivities impacting financial institutions and othersin the payments industry. Washington Watch is alsoarchived in the EPCOR All-Member Community libraryof the Knowledge Community.EPCOR Knowledge Community—The EPCOR KnowledgeCommunity is a members-only, restricted platform thatfosters communication and collaboration between EPCORmembers and staff on payments-related issues. TheKnowledge Community serves as a channel for memberservices, peer-to-peer dialogue and committee activities. Ithouses useful links, white papers, research reports and more.Members may access the Knowldege Community via theEPCOR website or at community.epcor.org.Number 4EPCOR KANSAS CITY, MISSOURI - FALL QUARTER 2017Ask Mary: What Happened to My NOC? Hear Ye,Dear Mary: We send Notifications of Change on a regular basis, but we still seemany of the related entries coming in time after time with no change made. Whyaren’t our NOCs being acted upon?Communications and InformationThe Evolving Role ofCash in Paymentspage 6The Rule faced immediate criticism fromindustry participants and Republicansin Washington, who claimed thatthe Rule was predicated upon faultyresearch by the CFPB and that it wouldpresent much more of a boon to theplaintiff ’s bar than ordinary consumers.For example, the American BankersAssociation, Consumer BankersAssociation and Financial ServicesRoundtable, in their joint commentsto the rule, cited that in “87% of classaction settlements consumers receiveINSIDE: Have You Familiarized Yourself With the 2017 ACH Rules Changes?.pg. 1no compensation and in the rare caseswhere they do receive a cash paymentfrom a class action settlement, it willbe a pittance, inasmuch as the BureauStudy found that the average participantin the class actions who were grantedreward received 32.35.” Criticismagainst the Rule was particularly intensein this instance, likely because the Rulewould have affected a very large swathof the consumer financial services sector(unlike many other CFPB rules, whichtarget a particular product type).Congress relied upon a measureknown as the Congressional ReviewAct to repeal the Rule. This law allowsCongress to overturn a major regulatoryaction within 60 legislative days ofthe measure being published in theFederal Register. This course of actionhas limited historical precedent, as itis typically only used in the rare set ofcircumstances when there is a carry-overregulator from a prior administrationwhose position on a regulation isat odds with both a President andCongress controlled by the oppositionparty. (That is the current case with theCFPB, whose current director, RichardCordray, is a holdover from the Obamaadministration).The Congressional Review Act onlyrequires a simple majority in theSenate to pass, rather than the 60-votesuper-majority required for most otherlegislation. That threshold certainlycame in handy for Arbitration Ruleopponents in this instance, becausethe resolution passed by a razor-thinmargin of 51-50, with Vice PresidentPence casting the tie-breaking vote.All Democratic Senators (and twoRepublicans, Senators Lindsey Grahamand John Kennedy of South Carolina andLouisiana, respectively) voted against themeasure. The House of Representativespreviously voted to approve the measureback in July.The U.S. Path to Faster Payments.pg. 5“They’re Here!” Same Day ACH Debits Have Arrived.pg. 62017Washington Watch NovemberAccepting Check Payments at Your Small Business.pg. 710 Cybersecurity Tips for Small Businesses .pg. 1Protect Your Business Against Wire Transfer Fraud .pg. 1NACHA Launches Third-Party Sender Certification Program.pg. 3Understanding EMV Transactions Can Help Businesses Manage Liability .pg. 8Understanding OFAC Compliance: Why Your Business Needs to Be In the Know .pg. 440% of Small Businesses Never Recover from a Disaster .pg. 10Have You Familiarized Yourself10 CybersecurityWith the 2017 ACH Rules Changes? Tips for SmallBusinessesAs an Originator of ACH entries it isjust what the changes might mean to yourimportant for you to stay up-to-date withorganization?Download the 2017 ACH Rules Update forthe ACH Rules. Same Day ACH debitsBroadband and information technologybecame a reality on September 15, and theOriginating Companies to discover answersare powerful tools for small businesses toThird-Party Sender Registration Rule wentto your important questions. For furtherreach new markets and increase sales andinto effect September 29. Do you know howdetails on how these changes may pertain toproductivity. However, cybersecurity threatsthese changes might impact your businessyour specific Origination activities, contactare real and businesses must implement theand/or your relationship with your financialyour financial institution.institution? Or do you still have questions onbest tools and tactics to protect themselves,their customers and their data. Visitwww.fcc.gov/cyberplanner to create a freeAre you a Third-Party Sender?If your financial institutions suddenly asks questions about your business, don’t bealarmed! They are gathering information to provide to NACHA to comply with the newThird-Party Sender Registration Rule. To acknowledge the importance of these playersin the ACH Network, NACHA has launched their Third-Party Sender CertificationProgram. You can become NACHA Certified when they have met NACHArequirements for employing effective oversight of your business, understanding ACHrisk and compliance obligations, and demonstrating sound governance. Get moreinformation in the article on page 3 and from NACHA’s website.customized Cybersecurity Planning guide foryour small business and visit www.dhs.gov/stopthinkconnect to download resources oncybersecurity awareness for your business.Here are ten key cybersecurity tips to protectyour small business:1.Train employees in securityprinciples. Establish basic securityProtect Your BusinessAgainst Wire Transfer FraudAn old scam with the potential to impactbusiness executive, partner or trusted vendor.the bottom line has resurfaced: wire transferIn this scam, fraudsters target companiesfraud. Fraudsters target businesses throughmost likely to make wire transfers. Typically,email phishing scams by impersonating athe criminal gains access to the legitimatesee FRAUD on page 3practices and policies for employees,such as requiring strong passwordsand establish appropriate Internetuse guidelines that detail penaltiesfor violating company cybersecuritypolicies. Establish rules of behaviordescribing how to handle and protectcustomer information and othervital data.E PCOR Insi d e Ori g i nat i o n Octo ber 2017see TIPS on page 21Continued next page1

Communications and InformationEPCOR Industry Updates—Stay up-to-date on the latestinitiatives, rules and regulations that impact all financialinstitutions and businesses. Hosted as live webinars andthen conveniently made available on-demand in theKnowledge Community, these updates provide timelyinformation on evolving payments industry initiatives. Freeto EPCOR members, and eligible for AAP credits.Special Industry Updates—Scheduled as needed toallow you to learn about and express your views onpending rules proposals and requests for comment in awebinar format. Free to EPCOR members. Registrationis required. Select recordings are available in the EPCORAll-Member Community Library.ACH Rules—A current copy of the ACH Rules isessential to maintaining compliance with the rules andregulations that govern the ACH Network. EPCORmembership guarantees your organization receives anannual copy of the ACH Rules. Additional copies forfinancial institutions and Originators are available atdiscounted prices at www.epcor.org.EPCOR Executive Exchange—Specifically designed forsenior executives of our member financial institutions,the EPCOR Executive Exchange provides a forum forpeer-to-peer dialogue and “need-to-know” informationon payments strategies, trends and new initiatives,as well as important risk-related topics to help assurecompliance.ACH Quick Reference Guide—All members haveaccess to the annually-updated, plain-English guidethat explains RDFI responsibilities and obligationsin an easy-to-reference format for those who find theACH Rules difficult to navigate. Return Reason codes,NOC codes and an ACH Terms Glossary are included.All members may download a complimentary copyin the EPCOR All-Member Community library of theKnowledge Community.Virtual Vendor Showcases—These free, 60-minutewebinars offer you an opportunity to learn aboutproducts and services in a hassle-free environment. Ifyou are in the market for a particular product or serviceor just want to learn about the latest offerings from aparticular vendor, these Virtual Vendor Showcases offera cost-effective solution to evaluating what’s available.If your organization is interested in presenting yourproducts or services to the EPCOR membership, pleasecontact memserve@epcor.org.EPCOR Product Showcases—These free webinarshighlight the features of various EPCOR publications andtools, including intended audiences, instructions for useand interactive demos.10 2018 EPCOR Member Benefits & Services Catalog

A forum for peer-to-peer dialogue and “need-to-know”information, specifically designed for senior executivesof our member financial institutions.EPCOR Executive ExchangeThe EPCOR Executive Exchange provides Presidents/CEOs, CFOs and other senior executives of EPCORmember financial institutions a forum for peer-to-peerdialogue and “need-to-know” information on paymentsstrategies, trends and new initiatives, as well as importantrisk-related topics to help assure compliance.EPCOR Executive Exchange offerings include periodicwebinars and communications on relevant topics. Inconjunction with the Executive Exchange, EPCORconducted a payments benchmarking study in early 2017to help members assess their payments products andservices offerings in the context of peer institutions, Seepage 50 of this catalog for details.If you are interested in participating in the EPCORExecutive Exchange, please contact contact Jen Kirk atjenk@epcor.org.Payments decision makers and members of the EPCOR Executive Exchange haveaccess to a special website dedicated

audit, security, risk management and fraud questions and concerns . Our AAPs, NCPs and risk/fraud specialists are available to help answer your questions at any time by phone, fax or via email . Member support is free and available only to EPCOR members . EPCOR recognizes that our members have different needs .