As an organization, you have an important obligation when taking ACH/eCheck payments processed via Shulware Integrated Payments (SIP): obtaining from payers authorizations compliant with ACH (Automated Clearing House) network requirements.
An ACH authorization is a payer’s consent to the initiation of an electronic funds transfer between payer’s financial institution account and the financial institution account associated with your SIP merchant ID. The authorization must be easily recognizable as an ACH authorization, contain clear and understandable payment terms, and inform the payer how to revoke the authorization. You must securely maintain a record of the authorization for two years from the date of a one-time payment or the date that a recurring payment series ends or is terminated.
Various elements of ShulCloud, such as the audit log and checkboxes in the payment flow, document online authorizations by payers. For non-web, admin-initiated ACH/eCheck payments, you must adopt appropriate practices to obtain and maintain authorizations, such as requiring the completion, signing, and dating of a paper form. While exceedingly rare, violation of ACH industry rules can lead to hefty fines for non-compliance and suspension of the ability to take ACH/eCheck payments.
A compliant ACH authorization will include this information:
- Full name of the payer
- Routing and account number of the payer’s financial account
- For a one-time payment, the payment date and amount
- For a recurring payment, the payment series start date, end date, frequency, and amount
- Date and time payer is granting the authorization
- How the payer can revoke the authorization to prevent further processing
- Your phone number to assist the payer with any questions
- Evidence of the payer’s consent, such as a dated signature on a form with the above details
It is also a good idea to note the purpose of the payment (e.g. to pay dues or religious school fees).
Taking ACH/eCheck Payments Over the Phone?
Do you take ACH/eCheck payment information over the phone and then process payments (and refunds) via SIP using that information? If so, the best practice is to record audio of that portion of the call granting authorization. We further recommend that a person taking the payment information by phone follow a script that clearly states the particulars above and requests and requires the caller’s authorization to proceed. If recording is not possible, we recommend that you direct the caller to the web site to enter the information themselves. If that is not feasible, mail or email the caller a form with the above information and require its return, signed and dated, before proceeding with a payment. Include the caller's phone number. One way or another, it is important to obtain documentary proof of the payer’s authorization prior to initiating an ACH/eCheck payment using the payer’s account.
By following the above, you protect your payers, your organization, and your ability to accept ACH/eCheck payments now and in the future.
For legal questions, please contact your legal counsel. For other questions, please contact support at questions@shulcloud.com.