Originators Responsibility Checklist:

• Review IAT Scenarios

• Review existing vendor, employee and pension payments and databases for possible IAT applications:
  • Foreign wire transfers (convert to IAT and save money!)
  • Foreign addresses (anything outside of the U.S. territorial jurisdiction)
  • Foreign vendor relationships

• Communicate with companies, employees and retirees to confirm payments are not leaving US borders

If after completing the three steps above you do not find any ACH entries meeting IAT requirements, you DO NOT need IAT.

• Have the individual with signing authority for the Company sign:
  • the Electronic Payments Agreement August 26, 2009 which is required regardless of the need for IAT services
  • the eBusiness IAT Certification which is required to confirm that IAT services are not required

• Fax the above two documents to eBanking at 989.633.3800 and then mail the hard copies to eBanking, 333 East Main Street, Midland, Michigan 48640.

If you find that you WILL NEED IAT, please read on.

• Familiarize yourself with new rules related to IAT, pages 20 - 26 (ACH Rules)

• Review your existing OFAC compliance policy if you have one (Additional OFAC Information)

• Secure IAT services on eBusiness Banking: Indicate that IAT is needed on the eBusiness IAT Certification form and return it with the Electronic Payments Agreement August 26, 2009 so that services can be established in advance of your first IAT origination

• Obtain new authorizations to include all of the required IAT information and initiate payments with the IAT transaction type as IAT to avoid penalties and fines

Additional Information:

• Existing eBusiness Banking ACH customers will be provided with a new Electronic Payments Agreement and eBusiness IAT Certification that must be signed and returned. They should have received packets in the mail with the following documents:
  • Copy of the letter sent to the Company Administrator of all eBusiness Banking (and MVP ACH Direct) ACH companies
  • Electronic Payments Agreement August 26, 2009
  • eBusiness IAT Certification
  • A self-addressed stamped envelope
• New Customers after August 26, 2009 will be required to utilize the new agreement documents. We anticipate a short transition period and will require any businesses who submit application and agreement versions dated prior to 8/26/2009 to sign the new agreement as if they had been an existing customer.
  • eBusiness Banking Application & Electronic Payments Agreement August 26, 2009
  • eBusiness IAT Certification