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Citizens for ACH? #3366

Closed chadwhitacre closed 9 years ago

chadwhitacre commented 9 years ago

http://www.citizensbank.com/commercial/automated-clearing-house-ach.aspx http://www.citizensbank.com/commercial/accessglobal-ach.aspx https://www.citizensbank.com/commercial-banking/banking-needs/electronic-payments.aspx

chadwhitacre commented 9 years ago

I called the 877 number and apparently we don't have the right type of account(?). They're having someone else call me back. I think I'm going to stop in the local office to talk with my contact there.

chadwhitacre commented 9 years ago

Called my contact at Citizens' local office and she's looking into this for me.

chadwhitacre commented 9 years ago

"There's an underwriting process, it's not an instant sign-up."

chadwhitacre commented 9 years ago

Local contact has me in the system and I'm waiting for a call from the next level up.

chadwhitacre commented 9 years ago

Just had a call with the next level up. She's going to get me a pricing sheet in the next day or so but sounds like they're offering 20¢ per. I did specify that we want to upload NACHA files programmatically and I think she took that on board (good look on recommending we make that explicit, @sbrendtro). I also emphasized that we're only doing credits, and aren't asking to be underwritten for debits at this point (maybe in the future). Seems to be moving along!

sbrendtro commented 9 years ago

As you get talking to more technical people at Citizens, you'll want to get a hold of their specifications for file transmission, file confirmations, and their NACHA format guide. The NACHA format itself is standard, but each bank seems to like to customize the values transmitted in some of the fields. And the file confirmation format is completely different for each bank. All of this information will be needed to build an OpenACH bank plugin specific to Citizens.

chadwhitacre commented 9 years ago

Meeting next Thursday at 10am to discuss.

chadwhitacre commented 9 years ago

Per https://github.com/gratipay/gratipay.com/issues/3390#issuecomment-100531709, ask Citizens about bank transfers outside the U.S.

sbrendtro commented 9 years ago

FYI, international ACH transfers are available through side banks, but to my knowledge the country lost no longer includes Euro countries since 2009 and the introduction of SEPA payments. The transfers could likely be done via:

  1. Bank wire (FedWire) - expensive
  2. SEPA - needs euro bank relationship
  3. OCT transactions to debit cards (direct to card loads) - Citibank does these and probably others, but not sure who. Read more here: https://developer.visa.com/vpp/documents/json/Original_Credit_Transaction__OCT_.html On May 9, 2015 8:57 PM, "Chad Whitacre" notifications@github.com wrote:

Per #3390 (comment) https://github.com/gratipay/gratipay.com/issues/3390#issuecomment-100531709, ask Citizens about bank transfers outside the U.S.

— Reply to this email directly or view it on GitHub https://github.com/gratipay/gratipay.com/issues/3366#issuecomment-100572106 .

chadwhitacre commented 9 years ago

Thanks @sbrendtro. I believe Citizens is owned by RBS, so they may be able to help us with a European bank account that we could use for SEPA. I'll ask about that on Thursday.

chadwhitacre commented 9 years ago

Reticketed from https://github.com/gratipay/gratipay.com/pull/3408/files#r30277011: ask about any temrs of service for end-users and language to use to incorporate their terms of service into ours.

chadwhitacre commented 9 years ago

Meeting went well. Lots of info but I'm running hard on #3415. We should see a proposal tomorrow, will need to make a decision tomorrow to make this happen in time (guy is on vacation next week, needs to get the ball rolling before he leaves).

chadwhitacre commented 9 years ago

I pulled the trigger on this. It'll be an adjustment because the fee structure and API are more complicated. One interesting development: we'll have access to 25 countries via IAT (cf. https://github.com/balanced/balanced-api/issues/44). We've actually had no fee on payouts since Balanced made an exception for us as an early adopter. Given the more complicated fee structure here, it'll take some work to figure out how we're going to pass that through; reticketed as #3443.

chadwhitacre commented 9 years ago

I told him we would move forward with the file gateway proposal, except for Achieve Access ($50/mo). Not having Achieve Access means:

Should I ask him to add Achieve Access after all?

chadwhitacre commented 9 years ago

I've said yes to Achieve Access at $25/mo. I've named @clone1018 as the secondary employee for dual-control purposes (after a short phone call with Luke).

chadwhitacre commented 9 years ago
Countries

Austria • Belgium • Canada • Cyprus • Czech Republic • Denmark • Finland• France • Germany • Greece • Ireland • Italy • Luxembourg• Malta • Mexico • Netherlands • Panama • Poland • Portugal • Slovakia • Slovenia • Spain • Sweden • Switzerland • United Kingdom

chadwhitacre commented 9 years ago

We're expecting next week to have a new account opened and to hear back with next steps.

chadwhitacre commented 9 years ago

We have a new analyzed checking account open at Citizens. :money_with_wings: I need to put a little cash in there today. This will replace the New Alliance account.

We are getting a second account at Citizens, a money market account that will have 1% guaranteed interest for 12 months. This will replace our old escrow cold storage account at Ally. It has a $25,000 minimum. Depending on how #1383 goes, we may need to close this out if we're able to drop our escrow low enough.

chadwhitacre commented 9 years ago

Just double-checked: there's no penalty if we close the money-market account before the 12 months is up or anything like that.

chadwhitacre commented 9 years ago

I've started connecting New Alliance at Citizens so we can transfer funds online for the money market account. Awaiting verification deposits.

I'll probably just withdraw cash and walk it down the street for the escrow checking account, because that can be a much smaller amount (and really should be done today).

chadwhitacre commented 9 years ago

Transferred $100 into the escrow checking account yesterday. Awaiting verification deposits to enable online transfer before opening up the money market account.

chadwhitacre commented 9 years ago

Had a long call with our implementation manager to go over the documents she sent me. We have a weekly call scheduled for Thursdays to stay on track. Deliverables from us are executed documents and a NACHA file in this format. We need to make sure we're using the right SEC codes. Target at this point is to process on their system for the first time on June 11(!), with June 18 as our fall-back.

chadwhitacre commented 9 years ago

Average implementation time is 26 days, June 11 is 21 days, June 18 is 28.

chadwhitacre commented 9 years ago

Do you have a fax number, @clone1018? They need one on the application even though we don't have to actually use it.

clone1018 commented 9 years ago

@whit537 I have a personal work fax I'll email you.

chadwhitacre commented 9 years ago

Awesome, thanks! :D

chadwhitacre commented 9 years ago

We need to make sure we're using the right SEC codes.

Our treasury services rep at Citizens recommends "IIT [Includes CCD, CTX, IAT & PPD]." I would expect us to start out using CCD for paying out team owners, and PPD for paying out team members. As we strengthen our identity verification (#3289), we should see how that affects this (what about a team payout to a member who is actually a corporation and not an individual?). For cross-border payments we'll use IAT, of course.

chadwhitacre commented 9 years ago

To: Citizens

I've read and executed the following:

  • Certificate of Authority
  • Cash Management Service Order
  • ACHieve Service Request
  • ACHieve Single Administrator Request
  • Challenge Information Form (Chad)

Additionally, I have a public key ready for the Data Transmission Questionnaire.

A question on the Certificate of Authority: Gratipay is a single-member LLC that is treated as a sole proprietorship by the IRS. Therefore, should I add my SSN to the Certificate?

For the ACH Service Request, we have identified a fax number, but I am awaiting confirmation of Luke's current mailing address. I am also waiting for Luke's Challenge Information Form.

I understand we're supposed to send one email with all of the documents, so I will wait until I have everything before I send it all over. Please expect those from me on Wednesday morning at the latest.

chadwhitacre commented 9 years ago

Awaiting verification deposits to enable online transfer before opening up the money market account.

New Alliance account verified at Citizens.

chadwhitacre commented 9 years ago

To: Citizens

Please find attached our executed documentation. Let me know if anything is missing.

I will follow up with the Challenge Forms, Data Transmission Questionnaire, and public key in a separate email.

To: Citizens

Here are the Challenge Forms for Luke and myself, as well as the Data Transmission Questionnaire and our public key.

I believe that's everything you need from us at this point, yes?

chadwhitacre commented 9 years ago

From: Citizens

I have the required agreements from you. But I was not able to open the attachment with the Public Key. Are you able to copy the key into an email and send that to me?

The last piece of the puzzle is an internal document that I need from your banker. I will begin the implementation as soon as I receive the internal document.

Let me know if you have any questions.

To: Citizens

Excellent. Here is the public key: [snip]

chadwhitacre commented 9 years ago

Let's consider this ticket closed when the "internal document" clears. Then we can move to #3488.

chadwhitacre commented 9 years ago

Had our weekly call with Citizens. The "internal document" is clearance from their underwriting department, who have bumped us to their AML department. In other words, https://github.com/gratipay/gratipay.com/issues/417#issuecomment-78266767 all over again. :-(

You know what? https://github.com/gratipay/inside.gratipay.com/issues/119

chadwhitacre commented 9 years ago

To: Citizens

Thanks for the call this morning. I understand that Gratipay needs to clear an underwriting hurdle with regard to third-party processors as well as AML before we have the green light to proceed. Per our call:

We show up on bank statements as GRATIPAY.COM plus our support phone number.

Here is a list of our current clients. Ball is in my court to get you a list of past clients for context (as you know we're in the midst of a major upgrade unrelated to our processing infrastructure migration and we're having to re-sign up our users).

On the AML documentation, I've asked [] in a follow-up phone call for a day to review and possibly refine our current practices in an effort to put our best foot forward with Citizens' AML department.

Please expect to hear from me again tomorrow.

chadwhitacre commented 9 years ago

Online transfer won't clear in time. If we're going to get this 1% rate locked in for the money market account, I need to go to New Alliance now and get a cashier's check and walk it down to Citizens and ask for next-day availability.

chadwhitacre commented 9 years ago

Okay! Money market account opened. O.o

chadwhitacre commented 9 years ago

:bank:                             :bike: :moneybag:     :bank:

chadwhitacre commented 9 years ago

@clone1018 has agreed to take a first pass at https://github.com/gratipay/inside.gratipay.com/issues/119 tonight, and I've approached @copiesofcopies about writing an opinion letter to Citizens to accompany the AML documentation.

chadwhitacre commented 9 years ago

Going to hold off on the opinion letter and see if we can schedule a call with the decision makers at Citizens if needed after they've had a chance to review what @clone1018 comes up with for an AML program. This is in line with Citizens' suggestion to me earlier today.

chadwhitacre commented 9 years ago

I need to get back to Citizens today about our AML program. Since we're down to the wire for implementation I don't think we can block on https://github.com/gratipay/inside.gratipay.com/issues/119. I think we should give them as much information as exists today, and ask if we can proceed with implementation in parallel with finalizing compliance.

clone1018 commented 9 years ago

Ouch, I had no idea you needed it by today, that would have been impossible. Sorry for the misunderstanding.

On Fri, May 29, 2015 at 2:23 PM Chad Whitacre notifications@github.com wrote:

I need to get back to Citizens today about our AML program. Since we're down to the wire for implementation I don't think we can block on gratipay/inside.gratipay.com#119 https://github.com/gratipay/inside.gratipay.com/issues/119. I think we should give them as much information as exists today, and ask if we can proceed with implementation in parallel with finalizing compliance.

— Reply to this email directly or view it on GitHub https://github.com/gratipay/gratipay.com/issues/3366#issuecomment-106908094 .

chadwhitacre commented 9 years ago

@clone1018 No, it's fine. I just had a call with our sales rep. I'm going to write something up describing where we stand today and the improvements we're planning for the future. He's going to hand that up the ladder, and we'll touch base next week. Outcomes I see are:

  1. They accept what we're able to come up with today and green-light us.
  2. They want to talk further, but are willing to let implementation proceed in parallel with underwriting.
  3. They want to talk further, and block implementation on underwriting.
  4. They reject us.

(1) is great, (2) would be a relief at this point. (3) would put us in a[nother] crunch, and (4), well ...

clone1018 commented 9 years ago

Couple of important notes from: http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf

P#14D10: No anonymous accounts or fake names? May not apply.

P#63H15: Enhanced CDD measures for "high risk", mentions geographic risk factors?

P#65H17c: countries with effective AML systems are low risk

P#65H20: Enhanced CDD measures

P#65H21: Simplified CDD measures (low risk) what we should be doing

chadwhitacre commented 9 years ago

@clone1018 Let's use https://github.com/gratipay/inside.gratipay.com/issues/119 for that.

chadwhitacre commented 9 years ago

To: Citizens

As you know, Gratipay's risk profile is actively changing right now, and we're doing our best to assess and respond to these changes quickly and carefully. Here is our risk management program as it stands today, which includes our AML program:

http://inside.gratipay.com/howto/manage-risk

We would welcome a conversation with Citizens' underwriters to further discuss any questions or issues related to our risk program.

Thanks, []!

chadwhitacre commented 9 years ago

From: Citizens

Thanks Chad We’ll be sure to update you with any feedback as soon as we get it. I anticipate [] and I will re-group with the AML and underwriting group now that we have those items they were most interested in to complete their due diligence.

To: Citizens

Thanks, []. After spending time with this over the weekend, I'm confident we can find a way forward together. I look forward to speaking with you on our Thursday call if not before, and I look forward to your decision to proceed!

chadwhitacre commented 9 years ago

@clone1018 Will you be able to join our weekly call at 11:30 AM US/Eastern today?

clone1018 commented 9 years ago

Sure, @whit537 it's in an hour right?

chadwhitacre commented 9 years ago

@clone1018 Yes, but actually, game off. I got a call this morning that we've been rejected.

chadwhitacre commented 9 years ago

The two reasons Citizens cited for rejecting us were:

I was speaking with a salesperson who was proxying about eight risk officers from an internal email thread. "You've even attracted the attention of the regulations and compliance department, which sits above AML." I've asked if we could have a conversation with one or more risk officers to understand their concerns, since that will be helpful in approaching PNC (#3518). Citizens went public last year, and that doesn't make them less skittish. The salesperson referred to "finable offenses," and in particular transactions involving sanctioned parties. It was unclear to me whether the identity of the sender or the receiver was the thing that mattered (cf. Transpay at https://github.com/gratipay/gratipay.com/issues/417#issuecomment-54667221).

Also, they noticed that Kiberpipa is in Slovenia. "Are they a registered charity? How do they know?" cc: @silverhook @domenkozar :)