ACH Implementation Guide for Electronic Funds Transfer: Industry

Transcription

1 ACH Implementation Guide for Electronic Funds Transfer: Industry NIPR Version 1.3 October 2012 NIPR NATIONAL INSURANCE PRODUCER REGISTRY For more information, please contact: NIPR Marketing Department

2 NIPR NATIONAL INSURANCE PRODUCER REGISTRY TABLE OF CONTENTS Introduction: What is ACH?... 4 How ACH Works for Electronic Funds Transfer (EFT)... 4 Implementing EFT Step 1: Request Participation... 5 Step 2: Determine Cash Accounting Procedures... 6 Step 3: Determine Detailed Accounting Procedures... 6 Step 4: Determine Licensing Procedures... 7 Step 5: Communicate Setup Configuration... 8 Step 6: Execute E-Commerce Agreement. 8 Step 7: Complete Testing and Certification... 8 Step 8: Implementation... 9 Contact Information October 22, 2012 Page 2 of 26

3 Introduction Although the term ACH Automated Clearing House encompasses a variety of technologies - credit card, wire transfer, private network/accounts, and Electronic Funds Transfer (EFT) - NIPR has limited the scope in this document to EFT. This technology is widely available, standard, secure and inexpensive. NIPR strives to utilize electronic payments whenever possible. NIPR does support electronic payment options of Electronic Check Processing, Credit Card Payments, and Electronic Funds Transfer (EFT), however this guide will only concentrate on the implementation of payment through EFT. Use of EFT allows benefits for moving data electronically with accuracy, timeliness, efficiency and cost reduction. This document will detail the ACH process of EFT for NIPR s ABPs/Industry Customers (hereafter referred to as Industry Customers) and will describe the steps required to implement ACH transfer technology for EFT when utilizing NIPR processes. How EFT Works The Industry Customers will enroll in the EFT payment option through NIPR. Setup for this process includes identifying the customer s chosen bank accounts and the Industry Customer providing authorization to the NIPR to withdraw funds. This process will certify NIPR to proceed. Only after proper certification through NIPR Marketing and thorough testing with NIPR Billing are complete, the NIPR will notify the Industry Customer that they can start sending transactions that will include licensing related State fees the NIPR will collect, and then send to the States via EFT processing. As is true today, Industry systems interface with the NIPR via Gateway transactions. The NIPR Gateway Layout Documents have been modified to include fields for an Industry Customer s account number and a payment code. The Industry Customer must update their transmissions to include this number and code. Access to this Layout Document is through a secure Sign-on, through NIPR Subscriber Services, available from our home page. Only NIPR Subscribers have access to this document. The NIPR system interfaces with a NAIC system called Centralized E-Commerce Initiative (CECI). This system provides a tracking number to NIPR that allows for detailed transaction tracing capabilities. On a daily basis (with exceptions for banking holidays) the CECI system summarizes all of an Industry Customer s transactions and produces a single EFT transaction per account. Of the many available EFT type transactions, CECI uses two: CTX (Corporate Trade Exchange) and CTX Addenda transactions. October 22, 2012 Page 3 of 26

4 1) One CTX transaction is analogous to a check. 2) The CTX Addenda transactions (1 to 9,999 per CTX transaction) serve as an envelope to contain ANSI x.12 EDI 820 Transactions. These transactions provide detailed licensing information, and travel through the banking system along with the CTX transactions. The CTX transactions pull money from the bank account of the Industry Customer, places the funds in the NIPR account and then pushes the money from the NIPR account to the appropriate State bank accounts. The NIPR uses national banking and Electronic Data Interchange (EDI) standards to provide the widest possible interoperability among its trading partners. To verify processing for daily Industry Customers, EFT transactions are recorded and communicated on NIPR s E-Commerce Report. This report is available via NIPR s Gateway Reports and is secure and available only to the particular Industry Customer that transmitted the transactions as well as to the States that receive the deposit and the transactions. There is a wide variety of selection criteria available at both the summary and detail levels, and the report is available with or without header information. There are various E-Commerce report options to assure the information can be received in a desired format and one, if desired, that can be incorporated into the Industry Customer s system. The formats available are HTML, PDF, Excel or Delimited. Implementing the EFT Payment Option Although there are only eight steps to implement EFT, it generally takes up to four functional areas within an Industry Customer organization to complete the set up process. 1. Those responsible for administering the firm s bank accounts generally the Accounting Department 2. Accounts Payable for Industry 3. Those responsible for licensing transactions 4. Technical Personnel responsible for integrating with external sources The following steps need to be followed for full implementation. October 22, 2012 Page 4 of 26

5 Step 1: Request Participation Objective The Industry Customer will indicate the desire to participate with NIPR in a process for Electronic Funds Transfer as an option for payment of State fees associated with NIPR processes. The Industry Customer will indicate a commitment for testing and implementing this option by cooperating with NIPR. Process Complete the E-Commerce Agreement in Exhibit A and return this signed document to NIPR Marketing. Step 2: Determine Cash Accounting Procedures Objective Correctly account for cash flows from or to company bank account(s) and develop the journal entries to any company-specific general ledger account(s). Ensure that the process meets security, authority, and auditing standards for your company. Process Generally this step is performed by the Industry Customer or State s Accounting Department. Sometimes this step is combined with the next step. There are several techniques available. Although not exhaustive, these instructions will provide a starting point for how your company will implement EFT payment processing. 1. Read ACH transmission from the bank: Since the NIPR, through NAIC Finance, uses standard banking transactions, you may be able to leverage banking processes already in place. Most banks can provide a copy of ACH transactions affecting the Industry Customer s account. Many standard accounting packages are able to read ACH format files. The CTX transaction contains the amount of the withdrawal and descriptive information. Included in the descriptive information, is an up to 15-character identifier, provided by the Industry Customer for a specific number that could map to their general ledger account. If your firm does not currently have the ability to decode ACH transactions, this will require a technical change to your systems. If you are already receiving some ACH formats, adding the CTX format will be a relatively minor change. See Exhibit C for details on how the NAIC and NIPR uses the company reference fields contained within the ACH transaction. October 22, 2012 Page 5 of 26

6 2. Use current banking documents to record transactions manually: ACH withdrawals, as do all withdrawals appear on the monthly bank statement. The date and descriptive information should make it possible for the Industry Customer to create manual journal entries for each day, or on a summary basis. Amounts may be verified by using the NIPR E- Commerce Report. The E-Commerce report is available only through an ID and Password provided by NIPR Marketing, and accessible through the Log in to Subscription Services available from the NIPR Home page, NIPR.com. 3. Use NIPR E-Commerce Report to make manual entries: This technique reverses option 2. In this case, entries are made on a daily or summary basis based on the NIPR E-Commerce report. Amounts are verified against the bank statement on a monthly basis. Step 3: Determine Detailed Accounting Procedures Objective Correctly account for the licensing fees paid. Ensure that the process meets Industry Customer security, authority and auditing standards. Process This step may be combined with either step 2 or 4, or may stand on its own. The technique used will depend on how the other steps are implemented. 1. Read CTX Addenda records and 820 details: If your bank provides detailed EFT transactions, the transmission will include both the CTX and CTX addenda records. The CTX Addenda records act as an envelope to ANSI x.12. See Exhibit C and D for CTX Format Information. EDI 820 records affect the company s account. Some standard accounting packages are able to read CTX Addenda records, including the EDI 820 records. The 820 records provide detailed information about individual transactions who, why, and how much. Included in the data are transaction identifiers that allow you to tie the information back to the NIPR system. If your firm does not currently have the ability to decode EDI 820 transactions, this will require a technical change or new system. This may be a moderately difficult task since there are several records within the 820 record set, and they are compressed within the CTX Addenda record. See Exhibit D for details about how the NAIC uses the EDI 820 transaction set. October 22, 2012 Page 6 of 26

7 2. Obtain 820 data/report from your bank: Although 820 translations are not necessarily widespread within industry, most banks have this capability. Your bank may be able to provide either 820 reports or data. If this information is used primarily for auditing purposes, this may suffice. 3. Use NIPR E-Commerce Report: The NIPR E-Commerce Report contains detailed information about license related transactions, processed through the Gateway and the associated State fee information concerning those transactions. The report is available over a selected time frame, and is available in Microsoft Excel format as well as HTML, PDF and Delimited formats. Step 4: Determine Licensing Procedures Objective The licensing department must be able to identify the detailed, processed transactions that are directly associated with a State fee bank deposit. Process In many cases, the detailed licensing information must be recorded in an Industry Customer system. Using a technique that includes data transfer would be most appropriate. The techniques for this step are very similar to those in the previous step. 1. Read CTX Addenda records and 820 details: Financial, licensing, and demographic data are included on 820 transactions. If your firm has the ability to read 820 data, this would be the easiest way to interface the licensing system. Any automated interface with your licensing system would require a technical change. See Exhibit D for details about how the NAIC and NIPR uses the EDI 820 transaction set. 2. Obtain 820 data/report from your bank: This option is identical to Option 2, Step 3. If you do not require an automated interface, this may be a viable option. 3. Use NIPR E-Commerce Report: The NIPR E-Commerce Report contains detailed information about licensing related transactions. Since it is available in Microsoft Excel format, it may be possible to integrate with an Industry Customer system. October 22, 2012 Page 7 of 26

8 Step 5: Communicate Setup Configuration Once you have made the decisions about how you will implement E-Commerce, you must communicate that to the NIPR staff. Complete the E-Commerce Configuration Template found in Exhibit B Step 6: Execute E-Commerce Agreement By definition, E-Commerce is the movement of money in electronic form. NIPR must have the authority to access Industry Customer accounts. The E-Commerce agreement (see Exhibit A) must be properly executed before testing can begin. For questions about the contents of the agreement, please contact: Ms. Sarah Heidenreich NAIC Legal Counsel sheidenreich@naic.org Step 7: Complete Testing and Certification There is no test banking system, so thorough component testing is vital. This testing must be carefully coordinated between the Industry Customer and NIPR. The E-Commerce process is a closed-loop system. Data originates and terminates at the Industry Customer. The NAIC and NIPR will help coordinate the following testing process: 1. Unit Test The purpose of the unit test is to ensure that the Industry Customer system can properly handle ACH for 820 transactions. The Industry Customer staff will send a test transaction file that will contain specified data conditions to NIPR. NIPR will process the file and return results to the Industry Customer in a timely manner. This procedure will ensure the Industry Customer can properly submit and process ACH transactions. 2. Pre -Notification Test This test is performed by the NIPR. Once the banking information is received, the pre-note process verifies that the account information has been entered accurately and is capable of electronic funds processing. 3. Penny System Test The purpose of the system test is to ensure that communications work among all parts of the system. The Industry Customer staff will send another test transaction file that will contain specified data conditions to NIPR. NIPR will originate the transmission of approximately ten test transactions, for $0.01 apiece. Due to the fact that there is no test banking system, these transactions will occur through the normal banking system, and your account will be debited $0.10 plus October 22, 2012 Page 8 of 26

9 bank processing fees, if applicable. All reports and transaction files will be processed using the same process as production. If requested, this step may be repeated until all parties are satisfied the process performs accurately. 4. Final Production Test Essentially this process is the same as the Penny test. However, 1 to 3 live production transactions will be submitted to NIPR. Full fund amounts will be withdrawn from the Industry Customer bank account via EFT and transferred to the appropriate State Departments of Insurance also via EFT. Additional testing of the various steps can occur at the Industry Customer s request Step 8: Implementation Once NIPR and the Industry Customer agree on the success of the transactions, the Industry Customer will notify the NIPR in writing of the official begin date for ACH processing for EFT. Both parties should monitor the system closely during the first week to ensure that things are processing appropriately. NIPR will also check with the State to insure State fees are received and E-Commerce reports reflect correct payment and transaction data. CONTACT INFORMATION Set-Up or General Inquiries NIPR Marketing Testing and Implementation NIPR Gateway Support eft@nipr.com marketing@nipr.com October 22, 2012 Page 9 of 26

10 Exhibit A: Electronic Funds Transfer Agreement, Authorization for Electronic Debit and Credit Entries, EFT Enrollment Form Exhibit B: E-Commerce Configuration Template Exhibit C: CTX Format Exhibit D: EDI 820 Transaction Set October 22, 2012 Page 10 of 26

11 Exhibit A ELECTRONIC FUNDS TRANSFER AND INDEMNIFICATION AGREEMENT This Electronic Funds Transfer and Indemnification Agreement ( EFT Agreement ) is entered into on this day Year 20 by the National Insurance Producer Registry ( NIPR ) located at 1100 Walnut Street, Suite 1500, Kansas City, Missouri and ( Company ) located at A. NIPR is a Missouri nonprofit corporation providing information and services to facilitate the uniform licensing of insurance producers. B. NIPR and Company have entered into an NIPR License Agreement ( License Agreement ) in which NIPR provides access to the NIPR Gateway for the Company to perform NIPR Gateway licensing related transactions. C. Pursuant to the License Agreement, Company is required to submit to NIPR transaction fees for the above-referenced transactions and is also required to remit State Insurance Department fees for licensing transactions which are then forwarded by NIPR to the appropriate State Insurance Department. D. NIPR and Company desire to utilize the Automated Clearing House Operating System for purposes of allowing the Company to electronic ally submit the State insurance department fees ( DOI Fees) through and Electronic Funds Transfer (EFT) process. E. The parties intend for the Electronic Funds Transfer Agreement to govern the party s respective rights and obligations relating to utilization of the Automated Clearing House Operating System for the above-stated purpose and do not intend to supersede or affect the party s obligations under the License Agreement. NOW, THEREFORE, in consideration of the mutual promises and agreements contained herein, it is hereby agreed to as follows: 1. AUTHORITY Company hereby authorizes NIPR and/or its agent, namely the National Association of Insurance Commissioners ( NAIC ), to initiate debit entries and, if necessary, credit entries and adjustments through the Automated Clearing House ( ACH ) Operating System for the purpose of (EFT) electronically transferring State Fees from Company to NIPR. October 22, 2012 Page 11 of 26

12 2. NIPR S OBLIGATIONS a. NIPR will initiate a daily electronic process to debit the Company s bank account through the ACH Operating System for the amounts due the State insurance departments based on the electronic calculation of the State Fees incurred by the Company as a result of the number of transactions, including NIPR Gateway licensing related transactions as submitted by the Company on its own behalf or on behalf of its customers. b. NIPR will initiate a daily electronic process to transfer to the appropriate State insurance departments bank accounts through the ACH Operating System the amounts due to the State insurance departments based on the electronic calculation of the number of licensing transactions submitted to NIPR by the Company. c. NIPR will, if necessary, initiate an electronic process to credit the Company s bank account through the ACH Operating System for any a mounts due the Company by NIPR. NIPR will not credit the Company s bank account for any amounts due the Company by NIPR or a State insurance department if NIPR has already sent the fee for the transaction at issue to the State insurance department. 3. COMPANY S OBLIGATIONS a. The Company will provide the information required in Exhibit A as well as hereby authorizes the NAIC to disclose, if necessary, the information in Exhibit A to the NAIC s financial institution and to the Company s financial institution. b. The Company will, at all times, have sufficient funds in the bank account identified in Exhibit A to cover the amount of State Fees incurred by the Company as a result of the number of licensing transactions performed by NIPR on behalf of the Company. c. The Company also agrees to indemnify and hold harmless NIPR for any and all existing or future obligations, indebtedness or liabilities owed by the NIPR to NIPR s financial institution and/or the State insurance departments caused directly or indirectly by the Company s failure to have sufficient funds available to cover State Fees at the time NIPR s debit entries were processed through the ACH Operating System. Within five (5) days after NIPR incurs an obligation, indebtedness or liability caused directly or October 22, 2012 Page 12 of 26

13 indirectly by the Company s failure to have sufficient funds available, the Company shall reimburse the NIPR for all amounts NIPR was required to pay to satisfy said obligation including penalties and other charges. For amounts not paid within five (5) days, interest shall accrue at the rate of Nine and One-Half Percent (9.5%) compounded annually until said amounts including interest are paid in full. The Company s indemnification and reimbursement obligations hereunder are unconditional and are independent of and exclusive of any defenses, claims or set-offs the Company may have against its financial institution, its customers, or the organization(s) directly or indirectly responsible for causing the Company s failure to have sufficient funds. 4. DISCLAIMER AN D LIMITATION OF LIABILITY The Company acknowledges NIPR will not determine the sufficiency of funds available from the Company s account to cover DOI Fees prior to the time NIPR transfers the DOI Fees to the appropriate State insurance departments. The Company agrees NIPR shall have no liability to the Company for transferring DOI Fees to the appropriate State insurance departments on behalf of the Company or its customers even though the Company does not have sufficient funds available to cover the DOI Fees. NIPR has MADE NO WARRANTY OR PROMISE, EITHER EXPRESS OR IMPLIED, with respect to the Automated Clearing House Operating System covered by this Agreement. NIPR expressly disclaims THE IMPLIED WARRANTY OF MERCHANTABILITY AND FITNESS FOR ANY PARTICULAR PURPOSE. NIPR SHALL NOT BE LIABLE FOR AND COMPANY EXPRESSLY WAIVES ANY CLAIM FOR ANY LOSS, COST, OR INJURY, DIRECT OR INDIRECT (INCLUDING, BUT NOT LIMITED TO, LOST SALES, LOST PROFIT, BUSINESS INTERRUPTION, OR THIRD PARTY CLAIMS), SUFFERED BY COMPANY AS A RESULT OF RELIANCE ON OR USE OF SAID PRODUCT. In the event of any dispute brought by Company against NIPR, it is mutually agreed and understood that Company s sole remedy and NIPR s sole liability shall in no event exceed the actual monetary amount transferred from Company s account to NIPR s account through the ACH Operating System, whether such claim is based on tort, negligence, or other legal or equitable theory. October 22, 2012 Page 13 of 26

14 5. NON -ASSIGNABILITY Neither party shall transfer or assign its rights or obligations under this Agreement without the express prior written permission of the other party. 6. GOVERNING LAW This Agreement shall be governed by and construed under the laws of the State of Missouri. 7. EFFECT OF AGREEMENT This Agreement governs the parties respective rights and obligations relating to utilization of the Automated Clearing House Operating system and does not supersede, modify or affect the parties obligations under the License Agreement. Where this Agreement is silent on a term or condition, the License Agreement will govern. Where the terms of this Agreement are inconsistent with the terms of the License Agreement, the terms of the License Agreement will govern. IN WITNESS WHEREOF, the parties hereto have executed this Agreement on the day and year first above written. National Insurance Producer Registry By: Company By: Title: Title: October 22, 2012 Page 14 of 26

15 Exhibit A (continued) AUTHORIZATION FOR ELECTRONIC DEBIT AND CREDIT ENTRIES The National Insurance Producer Registry ( NIPR ) and the National Association of Insurance Commissioners ( NAIC ) are authorized to initiate debit entries and to initiate, if necessary, credit entries and adjustments for the correction of any debit entries in error from or to the account indicated below of institution indicated below: Name of Financial Institution: Address of Financial Institution: Routing & Transit No: Account No.: Account Name (if applicable): **NOTE** Attach a deposit slip or voided check which shows the Routing and Transit Number & Account Number. The Company authorizes the above-named Financial Institution to honor such requests from NIPR or the NAIC and to debit or if applicable, to credit, the same to the account indicated above. The debit entries initiated by NIPR or the NAIC are for the payment of DOI fees as those terms are defined in the Agreement between the Company and NIPR. This authorization shall remain in full force and effect until the above-named Financial Institution as well as NIPR or the NAIC have received written notice from the Company of termination of authority in such time and manner as to afford the Financial Institution as well as NIPR or the NAIC a reasonable time to act on said termination. Notwithstanding the foregoing, this authorization shall terminate no later than thirty (30) days after written notice of termination is received by NIPR or the NAIC. Signature of Authorizing Party: Name & Title of Authorized Party: Name of Company: Address: Telephone Number: Date : October 22, 2012 Page 15 of 26

16 Exhibit A (continued) EFT Enrollment Form Company Name Treasury/Cash Management/Bank Account Manager Contact Name: Phone: Fax: Licensing Department Accounting/Accounts Payable Contact Name: Phone: Fax: Licensing Department Contact Name: Phone: Fax: October 22, 2012 Page 16 of 26

17 Exhibit B NIPR E-Commerce Configuration Template APPOINTMENTS Will you process and charge a fee for appointments electronically? Yes No Internal Account number for Appointments Bank Account Routing Number TERMINATIONS Will you process and charge a fee for terminations electronically? Yes No Internal Account number for terminations Bank Account Routing Number October 22, 2012 Page 17 of 26

18 NON-RESIDENT LICENSES Will you process and charge a fee for non-resident licenses electronically? Yes No Internal Account number for non-resident license terminations Bank Account Routing Number October 22, 2012 Page 18 of 26

19 Field # Data Element Name Field Inclusion Requirement Contents Length Position Field # Data Element Name Field Inclusion Requirement* Contents Length Position Exhibit C Transaction CTX Corporate Entry Detail Record 1 Record Type Code M Transaction Code M Numeric Receiving DFI Identification M TTTTAAAA Check Digit M Numeric DFI Account Number R Alphanumeric Total Amount M $$$$$$$$ Identification Number O Internal Account # Number of Addenda Records M Numeric Receiving Company Name/ID R Alphanumeric Number Reserved N/A Blank Discretionary Data O Alphanumeric Addenda Record Indicator M Numeric Trace Number M Numeric M Mandatory R Required O - Optional Transaction CTX Addenda Record 1 Record Type Code M Addenda Type Code M Payment Related Information O See 820 Layout Addenda Sequence Number M Numeric Entry Detail Sequence Number M Numeric October 22, 2012 Page 19 of 26

20 Exhibit D Transaction Set 820 Version 4010 ANSI Electronic Funds Transfer Segment: ISA INTERCHANGE CONTROL HEADER Loop: Max Use: 1 MANDATORY Level: ENVELOPE Max Use: PURPOSE: To start and identify an interchange of one or more functional groups. Data Element Name NAIC Codes/Values ISA01 Authorization Information Qualifier "00" ISA02 Authorization Information Ten blank positions. ISA03 Security Information Qualifier "00" ISA04 Security Information Ten blank positions. "01" for Production ISA05 ISA06 Interchange ID Sender Qualifier ID "ZZ" " " for Testing. ISA07 Interchange ID Qualifier "01" ISA08 Interchange Receiver Id ISA09 Interchange Date YYMMDD ISA10 Interchange Time HHMM Interchange Control Standards ISA11 ISA12 Identifier Interchange Control Version "U" "00401" = ACS X12. ISA13 Number Interchange Control Number ISA13/IEA02 Sequential Number. ISA14 Acknowledgment Requested "0" ISA15 Test Indication "P" for Production. "T" for Testing. ISA16 Sub-element Separator "~" October 22, 2012 Page 20 of 26

21 Exhibit D (continued) Segment: GS FUNCTIONAL GROUP HEADER Loop: Max Use: 1 MANDATORY Level: GROUP Max Use: PURPOSE: To start and identify a functional group of related transaction sets and provide control and application identification information. Data Element Name NAIC Codes/Values GS01 Functional Identifier Code "RA" = Remittance Advice GS02 Application Sender's Code " " GS03 Application Receiver's Code Vendor Routing Number GS04 Date CCYYMMDD. GS05 Time HHMM. GS06 Group Control Number GS06/ES02 Sequential Number. GS07 Responsible Agency Code "X" - X12. Version/Release/Industry Identifier GS08 Code "004010". Segment: ST TRANSACTION SET HEADER Loop: Max Use: 1 MANDATORY Level: HEADER Max Use: PURPOSE: To indicate the start of a remittance advice payment transaction set and to assign a control number Data Element Name NAIC Codes/Values ST01 Transaction ID "820" ST02 Control Number ST02/SE02 Sequential Number. October 22, 2012 Page 21 of 26

22 Exhibit D (continued) Segment: BPR BEGINNING SEGMENT FOR 820 Loop: Max Use: 1 MANDATORY Level: HEADER Max Use: PURPOSE: To indicate the beginning of a Payment Order/Remittance Advice and total payment amount. Data Element Name NAIC Codes/Values BPR01 Transaction Handling Code "C" = Payment Accompanies BPR02 Monetary Amount Amount BPR03 Credit/Debit Flag Code "C" for "checks" "D" for "deposits" from/to NAIC account BPR04 Payment Method Code "ACH" = Automated Clearing House BPR05 Payment Format Code "CTX" = Corporate Trade Exchange "01" = ABA Transit Routing BPR06 ID Number Qualifier Number BPR07 ID Number Number UMB ABA Transit Routing Number BPR08 Account Number Qualifier Code "DA" = Demand Deposit BPR10 Originating Company Identifier NAIC Company Identifier BRP12 (DFI) ID Number Qualifier "01" = ABA Transit Routing Number for Receiving Bank BPR13 (DFI) ID Number Number Receiving Bank ABA Number BPR14 Account Number Qualifier Code "DA" = Demand Deposit BPR15 Account Number Receiver's Bank Account Number BPR16 1 Effective Entry Date CCYYMMDD (Settlement Date) 1 Next Banking Day. Must account for weekends and bank holidays. October 22, 2012 Page 22 of 26

23 Exhibit D (continued) Segment: DTM DATE/TIME REFERENCE Loop: Max Use: 1 Level: HEADER Max Use: OPTIONAL PURPOSE: To specify pertinent dates and times. Data Element Name NAIC Codes/Values DTM01 Date/Time Qualifier "097" = Transaction Creation DTM02 Date CCYYMMDD Segment: N1 NAME Loop: N1 Repeat >1 Level: HEADER Max Use: 1 Max Use: OPTIONAL PURPOSE: To identify a party by type of organization, name and code. Data Element Name NAIC Codes/Values N101 Entity Identifier Code "PR" = Payer N102 Name NAIC Segment: N1 NAME Loop: N1 Repeat >1 Level: HEADER Max Use: 1 Max Use: OPTIONAL PURPOSE: To identify a party by type of organization, name and code. Data Element Name NAIC Codes/Values N101 Entity Identifier Code "PE" = Payee N102 Name Vendor Name N103 Identification Code Qualifier "1" = Duns Number N104 Identification Code Payee Duns Number October 22, 2012 Page 23 of 26

24 Exhibit D (continued) Segment: RMR REMITTANCE ADVICE/ AR OPEN ITEM Loop: ENT/RMR Repeat >1 Level: DETAIL Max Use: 1 Max Use: OPTIONAL PURPOSE: To specify the Accounts Receivable open items to be included in the cash application. Data Element Name NAIC Codes/Values RMR01 Reference Number Qualifier "IV" RMR02 Reference Number Invoice Number RMR04 Monetary Amount Monetary Amount RMR05 Total Invoice or Credit/Debit Document Amount RMR06 Amount of Discount Taken 0 Segment: REF REFERENCE NUMBERS Loop: ENT/RMR Repeat >1 Level: DETAIL Max Use: 1 Max Use: OPTIONAL PURPOSE: To specify identifying numbers. Data Element Name NAIC Codes/Values REF01 Reference Number Qualifier "DB" REF02 Reference Number PIN Transaction Number Trans Type 2 01-appt; 02 -term; 04-NRL PIN Batch 15 PIN Cust Trans 20 REF03 Description Name/Firm 30 Tax ID 9 Lic Class 4 October 22, 2012 Page 24 of 26

25 Exhibit D (continued) Segment: DTM DATE/TIME REFERENCE Loop: ENTR/RMR Max Use: 1 Level: DETAIL Max Use: OPTIONAL PURPOSE: To specify pertinent dates and times. Data Element Name NAIC Codes/Values DTM01 Date/Time Qualifier "003" = Transaction Creation DTM02 Date CCYYMMDD Segment: SE TRANSACTION SET TRAILER Loop: Max Use: 1 MANDATORY Level: SUMMARY Max Use: PURPOSE: To indicate the end of the transaction set and provide the count of the transmitted segments. Data Element Name NAIC Codes/Values SE01 Number of Segments Include ST and SE segments. SE02 Control Number ST02/SE02 Sequential Number. October 22, 2012 Page 25 of 26

26 Segment: GE FUNCTIONAL GROUP TRAILER Loop: Max Use: 1 MANDATORY Level: SUMMARY Max Use: PURPOSE: To define the end of a functional group of related transaction sets. GE01 Data Element Name Number of Transaction Sets Included NAIC Code s/values 2 Total Number of Transaction Sets. GE02 Group Control Number GS06/ES02 Sequential Number. 2 Include GS and ES Transactions Segment: IEA - INTERCHANGE CONTROL TRAILER Loop: Max Use: 1 MANDATORY Level: ENVELOPE Max Use: PURPOSE: To define the end of an interchange of one or more functional groups and related control. Data Element Name NAIC Codes/Values Number of Included Functional 3 Count of GS Segments in IEA01 Groups Transmission. IEA02 Interchange Control Number ISA13/IEA02 Sequential Number. 3 Include ISA/IE October 22, 2012 Page 26 of 26