According to Marsha Jones, TPPPA President, the CMS policies are designed to meet the specific needs and responsibilities of both processors and their financial institutions to support overall compliance. Furthermore, via CMS, TPPPA provides its processor and financial institution members the tools to navigate the sheer number of rules, regulations and guidance set by regulatory agencies and rule-making bodies, such as NACHA.
The processor module contains over 15 policies specifically written for payment and payroll processors that incorporate guidance for due diligence and enhanced due diligence. These policies include ACH, Red Flags, BSA/AML/OFAC, Privacy, Consumer Complaints, UDAAP, Compliance with Telephone Consumer Protection Act, Compliance with Fair Debt Collections Act, Compliance with Fair Credit Reporting Act.
The CMS processor module gives each processor the ability to customize their procedures to fit their unique processing environment while remaining in alignment with the associations standards.
The FI module is geared toward financial institutions that have third-party payment processors as their clients, and helps incorporate their existing policies into a cohesive program for third-party payment processing. This module highlights issues that a financial institution needs to address to ensure proper due diligence and ongoing monitoring and management of their processor relationships.
All policies have been created to address the oversight of relevant regulatory agencies, including FDIC, OCC, FRB and FinCEN.
Content included in both CMS modules focuses on broader categories, such as risk assessment (due diligence and underwriting), agreements, merchant training, ongoing monitoring, periodic review, and reporting suspicious activity and termination of merchant.
The Compliance Management System (CMS) will be launched at Payments 2014, NACHAs conference for the electronic payments industry.
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