Migration of mandates based on NBB file. version July

Transcription

1 Financial Supply Chain SEPA Migration of mandates based on NBB file version July

2 Background 1 Acquisition 1 Formats 1 DOM80 migration 2 Processing of the NBB migration file 2 SDD Mandate Reference & DOM80 mandate migration 2 Migrated Mandates 5 Tips & Tricks 6 DOM80 direct debit mandate numbers - duplicates 6 B2B mandates 6 Character set 6 Reachability of banks 6 Inactive mandates 7 Migration process 7 Structure of the NBB migration file 9

3 Background Since September 2009, all banks that offer customers the option of opening a Belgian direct debit mandate have been submitting a list with the electronic data of all of their known direct debit mandates to the National Bank of Belgium (NBB) on a monthly basis. This takes place on the 10th of each month. This list contains the DOM80 direct debit mandate numbers, the IBAN and BIC data, and the name and address of the debtor. The NBB keeps these DOM80 mandates in a migration file. When a direct debit mandate is migrated to a SEPA Direct Debit (SDD), the bank will remove this mandate from its list, and as a result it will disappear from the NBB migration file as well. The banks that offer domestic direct debit have engaged themselves to forward this data each month to the National Bank. Acquisition If you are a creditor and you wish to migrate to the SEPA Direct Debit, you can acquire the extract of your DOM80 debtors from the NBB migration file through your bank. ING requests the relevant information from the NBB, based on your DOM80 creditor identifier. ING then forwards this file to you. Requests made to the NBB are handled exclusively through the bank, and you can never ask this directly to the NBB as the creditor. ING sends you the file via (when the zipped file is less than 15 MB - maximum of 5 s) or burned to a CD and via post (when the zipped file size exceeds 15 MB). If you wish, you can also collect this CD in person at the Operational Centre in Ghent or Brussels. The easiest way to acquire this file with your mandates is to ask for it together with your request to become a SEPA Direct Debit Creditor. Should you have to demand for this afterwards, then please contact your commercial contact. Formats When ING receives the NBB migration file from the National Bank of Belgium, it comes in CIRI format without line breaks. You can also receive the file in CIRI format with line breaks upon request. This makes the file easier to read in a basic text editor such as Notepad. This format is also easy to import into a spreadsheet application such as Excel. It is also possible to receive the file in Access format, or in Excel format (depending on the size of the file). Migration of mandates based on NBB file 1

4 DOM80 Migration In order to migrate your DOM80 mandates to SEPA Direct Debit mandates, a number of actions must be carried out. Please find below some advice concerning the use of this file. Processing of the NBB migration file The purpose of the NBB migration file is to simplify the process of migrating your current DOM80 mandates to SEPA Direct Debit mandates by providing you with an overview of all of your current DOM80 mandates (electronic data); including the DOM80 direct debit mandate number, name and address of the debtor; converting BBAN into IBAN; attaching the corresponding BIC (Bank Identification Code); adding the contract number associated with these direct debits (reference or subscriber number) if this information is available and has been communicated by the debtor s bank. This file can be directly imported into your accounting software or customer management system, depending on its capabilities. If this is not possible, either your system will need to be reconfigured or changes to the format of the file will need to be made. Contact your vendor or IT department for more information regarding the options that are available when importing files into your systems. Your system should not only import the data of the file, but must of also allow the processing, modification and storage of the data. Some items to pay close attention to are the length of the codes (Belgian IBAN = 16 characters as opposed to the 12 characters in the Belgian BBAN) and the new BIC (maximum of 11 characters). Contact your vendor or IT department for more information regarding the options that are available when processing and storing this data. SDD Mandate Reference & DOM80 mandate migration The reference of a SEPA Direct Debit mandate is the key element to initiate the collection on the basis of all the information of the mandate that has been signed by the debtor. You (the creditor) may choose any SDD Mandate Reference that you like, but it may be no longer than 35 characters. Furthermore, this reference must be unique for each mandate and creditor. The DOM80 direct debit account number can be used as an SDD Mandate Reference when migrating the mandates, but this is not required. The choice is yours to make. We recommend keeping the SDD Mandate Reference as simple and logical as possible. It is essential that your accounting software supports your choice (it must be possible to store the SDD Mandate Reference) and that the migration of the DOM80 mandate to an SDD mandate is technically possible. The migration must be carried out by issuing a number of specific instructions when creating the initial collection of the SDD for the mandate in question. The mandate is migrated after a first successful collection. More information on this can be found in our brochure called XML format guide for Belgium - SEPA direct debit (SDD). Contact your vendor or IT department for more information regarding the options relating to the SDD Mandate Reference and the migration. Comments: In case you make use (as a creditor) of a software with conversion services, there are 2 possibilities: You have the choice between continuing with the DOM80 direct debit mandate number, or entering a new reference for the SDD mandate 1. You have no choice: the conversion software converts DOM80 input files that you introduce, into a SEPA XMLfile for SDD. In that case the SDD Mandate Reference will not appear on screen. You continue to work with the mandate number in DOM80 format, which provides only 12 characters. The conversion software makes the connection between the DOM80 direct debit mandate number and a new SDD Mandate Reference that is managed in a database on the background. 1 When choosing to use the DOM80 direct debit mandate number as the SDD Mandate Reference, the chance that a duplicate might exist must be taken into account. Migration of mandates based on NBB file 2

5 Creation of the first XML-file to migrate DOM80-mandates In case of a migration of DOM80 to the SEPA Direct Debit, the value FRST is mandatory at the first collection for the tag Sequence Type. This tag is located at the level <PmtInf> (batch level) and therefore valid for the whole batch. The tag MandateRelatedInformation is located at the level of the transaction <DrctDbtTxInf>, and is defined as: a series of elements that are used to provide with more detailed information about a Direct Debit mandate that the creditor and the debtor have signed. We advise you to group all DOM80-mandates that you wish to migrate in one single batch / <PmtInf> and to group the collections for mandates that are already migrated to SEPA (with the value RCUR for the tag Sequence Type ) in another single batch / <PmtInf> of the same XML-file. Considering the possibility that the debtor bank cannot debit the account of its client within 5 working days (2 for B2B) after the execution date, we advise you to wait minimum 2 days after the reception of the first collection before sending recurrent collections (RCUR) for newly created or migrated mandates (FRST). Example: <MndtRltdInf> Index Name XML Tag Occ. Format 2.48 MandateIdentification <MndtId> [1..1] Text 2.49 DateOfSignature <DtOfSgntr> [1..1] Date 2.50 AmendmentIndicator <AmdmntInd> [0..1] Boolean 2.51 AmendmentInformationDetails <AmdmntInfDtls> [0..1] TAG 2.62 ElectronicSignature <ElctrncSgntr> [0..1] Text Migration of mandates based on NBB file 3

6 If you construct your XML-files yourself, and you prepare your first collection (cfr. Sequece Type = FRST), then there are some rules to respect for the tag «Mandate Related Information» <MndtRltdInf> : The tags «Mandate Identification» and «Date of Signature» are always mandatory for all collections. In case of a mandate that is migrated from DOM80, you need to choose as «Date of Signature» the date of the migration. You need to fill in the value True for the tag «Amendment Indicator» The tag «Amendment Information Details» is defined as: the list of elements of a direct debit mandate that have been modified and is mandatory in case some aspect of the mandate has been modified (=> amendment indicator = True). <AmdmntInfDtls> Index Name XML Tag Occ. Format 2.52 OriginalMandateIdentification <OrgnlMndtId> [0..1] Text 2.53 OriginalCreditorSchemeIdentification <OrgnlCdtrSchmeId> [0..1] TAG 2.57 OriginalDebtorAccount <OrgnlDbtrAcct> [0..1] TAG 2.58 OriginalDebtorAgent <OrgnlDbtrAgt> [0..1] TAG In case of a migrated DOM80-mandate you need to fill in - As «Original Mandate ID» DOM80 followed by the original direct debit reference Example - As «Original CreditorSchemeIdentification» : > As «Identification»: first DOM80 and then the original Creditor Scheme Identification that you used for DOM80 (your Creditor Id). > As «SchemeName» under Other you need to fill in SEPA for the tag Proprietary ; Example Migration of mandates based on NBB file 4

7 Migrated Mandates A DOM80 mandate has only been migrated (to an SDD Core mandate) once the debtor s bank has collected for the first time the amount from the debtor s account. Immediately following this collection, the debtor s bank will deactivate the DOM80 mandate and mark it as having been migrated. From that point forward, the DOM80 mandate can no longer be used, nor will it be possible to reactivate the DOM80 mandate in the future. The migration of a DOM80 mandate to an SDD mandate is final and irreversible! The migrated DOM80 mandate is no longer included in the list that is sent to the National Bank of Belgium every month, and as a result it disappears from the NBB migration file as well. Please note that there is no time restriction on the validity of a DOM80 mandate, unless: it is explicitly revoked by one of the parties involved (revocation); the DOM80-mandate has been migrated to an SDD mandate. An SDD mandate, on the other hand, is no longer valid 36 months after the last collection. Migration of mandates based on NBB file 5

8 Tips & Tricks DOM80 direct debit mandate numbers - duplicates Before the migration, you need to check if there are no doublets among the DOM80 mandate references that appear in the list of the NBB. Should this be the case, then you must assure yourself that your accounting software reckons with this. In case your accounting software does not check for doublets, you will have to find a solution before migrating. You can distinguish the doublets of mandates by the field Mandate reference that has been added to the NBB migration file. It is possible that this field of 6 characters contains only zeroes, even if the DOM80 mandate numbers appear multiple times in the list. In that case we advise you to use the field Reference or subscriber number to distinguish the doublets. This number is the reference of the contract between the debtor and yourself (the creditor), to which the direct debit mandate is related. Should this field also be empty, than there remains the field Date original direct debit mandate was opened to distinguish the doublets. B2B mandates A current DOM80 mandate can only be migrated to an SDD mandate within the SEPA Core scheme. The SEPA B2B scheme is new; it comes with a specific set of rules, and it has no equivalent within the DOM80 system. Because of this, a new mandate always needs to be signed, which means that migration is not possible. This is not to say that the NBB migration file cannot be used when getting ready to create the new B2B mandates, for it does in fact contain all the information needed to fill out a B2B mandate form in advance. Character set The UTF-8 character encoding standard must be used in the XML (ISO 20022) messages for SDD instructions. Furthermore, the allowed characters are strictly limited to the character set: a b c d e f g h i j k l m n o p q r s t u v w x y z A B C D E F G H I J K L M N O P Q R S T U V W X Y Z / -?: ()., + Space Rules concerning the character set to be used in the lists or in the NBB migration file have not been enforced by either the banks or the NBB. As a consequence, the alphanumeric fields in the NBB migration file can contain characters that are not accepted in the SDD instructions. This can lead to problems within the payment channels that are used to forward the SDD instructions; ISABEL6: fatal error - your file has been rejected in full. Swiftnet Fileact: does not validate this character set. ING FTP: does not validate this character set. ING does not support the use of other characters, for this can cause the not passing on of this information to the ultimate destination, the rejection of the transaction in question, or the rejection of the complete file! It is recommended that the NBB migration file be checked beforehand for forbidden characters and to verify whether the accounting software will perform a conversion if necessary. If not, these forbidden characters will have to be removed/ replaced before migration. We advise you to use numbers only, and if necessary capital letters (upper cases), for your SEPA Direct Debit mandate references. You should also take into account that, at this moment, capital and small letters (upper and lower cases) are considered as different characters within the SEPA system. Reachability of banks Since 1 November 2009, all banks in the Euro area are reachable in the SDD Core scheme (as mandated by a European law). This means that banks offer the necessary services to process your SDD Core instructions. There is no such requirement in the Euro area for the SDD B2B scheme; this scheme is optional. In Belgium, all banks are reachable for the Core scheme, Migration of mandates based on NBB file 6

9 and you can issue SDD instructions without any problem if you have used the NBB migration file to migrate. In Belgium, a bit more care is in order when you wish to use the NBB migration file when getting ready to create your B2B mandates: Almost all Belgian banks are reachable in the SDD B2B scheme. When a bank is not reachable, there is no sense in having your debtor signed a mandate; the bank will still not be able to process your SDD instructions. You will have to come up with a different solution with your debtor (such as a Core mandate instead of a B2B mandate after all). You can find the reachability lists on the EPC website, via With the help of the BIC for the debtor s account, you can find out whether or not the bank is reachable in the scheme (participant or not). There is a list for the Core and a list for the B2B scheme. Inactive mandates The NBB migration file contains all the electronic data of the DOM80 mandates of the creditor. In many instances, there are also inactive DOM80 mandates that can be found here. Experience has shown that - even though the contract between the creditor and the debtor has been terminated - it is often omitted to inform the debtor bank that a DOM80 mandate needs to be deactivated. The consequences can be substantial for you (as a creditor) when these inactive DOM80 mandates are not removed prior to migration: they will be migrated as active SDD mandates; your ERP vendor can charge you on the basis of the number of administered mandates, and then you will also pay for the mandates that you are actually no longer need; ING is therefore advising you to check whether the NBB migration file contains inactive DOM80 mandates before using it for migration, and to remove any that are found out of your clients database. You can verify this with the help of the information in your accounting software. This would also be a nice opportunity to review your other data; the information in the NBB migration file represents the most recent information available to the banks, and it would be worthwhile to compare this with the information in your system. When performing these checks (on alphanumeric fields such as name and address), make sure not to do so on a case-sensitive basis. Information is entered into the NBB migration file in a combination of capital and small letters (upper and/or lower cases) - it depends on the input from the banks. Migration process As indicated previously, the migrated mandates are not included in the lists and are therefore also no longer included in the NBB migration file. Once you have begun your migration, the NBB migration file will get smaller and smaller each month as a result. This also makes it possible to follow up on your migration. It should be kept in mind that when new DOM80 mandates are generated during the migration period, these will likewise be included in the NBB migration file. When this happens, the reduction in the number of DOM80 mandates in the file will not equal the number of migrated mandates. It is also possible that smaller banks fail to submit their lists to the NBB on time. As a result, the DOM80 mandates of these banks will not be listed in the NBB migration file for the related month (without having been migrated to SDD mandates)! there is a chance that you execute SDD instructions on the basis of these inactive mandates, resulting in customer relations issues, demands for refund, etc. etc. Migration of mandates based on NBB file 7

10 End of the migration: When the migration of your DOM80 mandates is complete, please notify it to ING. Should you remark that some banks, even after you are fully migrated to SEPA, continue to create mandates within the old DOM80 system, do not hesitate to contact ING. ING can already block the creation of DOM80 mandates in its own branches (agencies). Furthermore, ING can launch the procedure to inform all Belgian banks, in cooperation with the NBB, that your migration has been concluded. The purpose is to inform all Belgian banks, so that they take the necessary measures to block the creation of new DOM80 mandates. Migration of mandates based on NBB file 8

11 Structure of the NBB migration file The migration file is comprised of a header record (record identifier = 0) and multiple data records (record identifier = 1), and is structured as follows: Header record Character positions # Type AN = Alphanumerical N = Numerical Description 1 1 N Record identifier = AN SDD application code 5 1 N File type = 2 (Download) N Protocol code of the receiving bank AN Protocol code of the (sub)-participant or blank N File creation date (DDMMYYYY) N File reference number N Total number of files N Number of data records N Identification number of creditor AN Blank Data record Character positions # Type AN = Alphanumerical N = Numerical Description 1 1 N Record identifier = N Record reference number AN Reference or subscriber number AN IBAN data of debtor (payer) N DOM80 direct debit mandate number or account number of payer N Mandate reference or zeros N Date original direct debit mandate was opened (DDMMYYYY) AN Name of debtor (payer) AN Address of debtor N Postal code of debtor AN City and country of debtor AN BIC of debtor s bank (8 + XXX or blanks) N DOM80 identification number of creditor N Date of most recent download (to be completed by NBB) Migration of mandates based on NBB file 9

12 ING Belgium SA/nv Bank Registered Office: Marnixlaan 24, B-1000 Brussels Brussels RPM/RPR VAT BE IBAN: BE Publisher: Inge Ampe Cours Saint-Michel 60, B-1040 Brussels E 07/13 Editing Team & Graphic Studio Marketing ING Belgium