On September 18, 2009, the new IAT Standard Entry Class (SEC) code will replace NACHA’s Consumer Cross-Border (PBR) and Corporate Cross-Border (CBR) SEC codes for international ACH transactions. This change will allow institutions to better identify international ACH transactions and help them comply with Office of Foreign Assets Control (OFAC) requirements.
In an effort to help measure industry-wide awareness of the IAT SEC code and readiness for implementation, the Federal Reserve Banks conducted a survey in March 2009. Most of respondents were financial institutions based in the U.S. Over half were community banks. This effort was a follow-up to a similar survey conducted in 2008.
Survey participants represented a variety of institution type and asset sizes. A summary of responses is shown below.
Overall, 21% of survey respondents consider themselves knowledgeable about IAT SEC codes. This is just slightly larger this year, compared to last year (21% in 2009 versus 18% in 2008).
| Institution Type | Extremely and Very | Somewhat | Not Very and Not At All |
|---|---|---|---|
| Regional Commercial Bank | 56% | 34% | 10% |
| Community or Savings Bank | 10% | 50% | 39% |
| Credit Union | 11% | 49% | 40% |
| Other | 20% | 47% | 53% |
More of those surveyed this year (28% in 2009 versus 18% in 2008) consider themselves knowledgeable about their organization’s roles and responsibilities (such as OFAC) associated with sending and receiving IAT items.
| Institution Type | Extremely and Very | Somewhat | Not Very and Not At All |
|---|---|---|---|
| Regional Commercial Bank | 61% | 28% | 11% |
| Community or Savings Bank | 19% | 56% | 25% |
| Credit Union | 21% | 57% | 21% |
| Other | 29% | 51% | 20% |
Nearly all (93%) of those surveyed expect to be ready to process IAT payments by September 2009 or before.
| Institution Type | Prior to the September, 2009 Effective Date | In Time for the September, 2009 Effective Date | We Have Concerns About Being Ready for the September, 2009 Effective Date |
|---|---|---|---|
| Regional Commercial Bank | 27% | 68% | 5% |
| Community or Savings Bank | 28% | 67% | 4% |
| Credit Union | 33% | 57% | 10% |
| Other | 50% | 50% | 0% |
Nearly two-thirds (64%) of those surveyed have read the new NACHA rules and/or attended an educational or training session, been in contact with their ACH software vendor about the new code or begun discussions with their compliance officer about receiving IAT items.
| Steps to Prepare for IAT | Already Taken | Expect to Take |
|---|---|---|
| Read the new NACHA rules and format | 64% | 34% |
| Attended an educational teleseminar or training session | 57% | 40% |
| Have been in contact with our ACH software vendor about the new code | 56% | 33% |
| Began discussions with our compliance officer about receiving IAT items | 53% | 39% |
| Contacted our RPA for assistance | 35% | 45% |
| Have been in contact with other software vendors about integrating the new code | 34% | 24% |
| Conducted an internal planning/training session | 26% | 65% |
| Began discussion with our originating customers about the new required data fields | 14% | 51% |
Most (73%) of those surveyed have not yet contacted customers about readiness to receive or send IAT-formatted items.
| Institution Type | Yes | No | Unsure |
|---|---|---|---|
| Regional Commercial Bank | 15% | 66% | 19% |
| Community or Savings Bank | 8% | 79% | 13% |
| Credit Union | 23% | 62% | 15% |
| Other | 0% | 100% | 0% |
For more information about IAT, please visit our resource center.
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