Fraud in the payments space is nothing new. In fact, it is fairly pervasive across the (now numerous) available payment systems. And despite the clear benefits of faster payments, the advent of faster, more easily accessible methods of payment has given rise to new opportunities for fraudsters.

From bill payment and payroll to the “behind the scenes” funds settlement mechanisms of various payment applications we use daily, one of the primary payment systems used by consumers and businesses alike is
Continue Reading Avoid the Pitfalls of ACH Fraud: Embracing Nacha’s New Risk Management Topics

For years, “FBO” has been one the payments industry’s favorite buzz words. The FBO account structure has been a common “best practice” by payments providers seeking to remove themselves from the flow of funds to reduce their risk of being regulated as a money transmitter. As a foundational matter, FBO accounts are merely custodial depository accounts maintained at financial institutions and established “for the benefit of” (FBO) intended beneficiaries of funds in the accounts. The structures of such accounts can
Continue Reading What is the Future of FBO Accounts?

As a corporation that handles ACH transactions on behalf of others, you may have heard your financial institution refer to you as a “Third-Party Sender.” Common examples of Third-Party Senders include payroll processing companies, rent payment companies, and other bill pay providers. If an entity is designated as a Third-Party Sender, it is subject to certain duties under the Nacha Operating Rules (“ACH Rules”), such as the requirements to have an annual ACH Audit conducted and to enter into specific agreements with its clients (the “Originators”).
Continue Reading Third-Party Senders: Are you a Money Transmitter?