If a US Company originates payments via the US ACH Network to US Receivers, but informs the ODFI that they will be receiving a transfer from a foreign account to fund the payments, is this an IAT?
Yes, this would be an IAT. 18. A Payroll Processor has a customer (referred to as Company) that is located outside the territorial jurisdiction of the U.S. All of the employees of this Company are located in the U.S. and the Company has an account at a Financial Institution within the U.S. The Company sends Wire Transfers periodically to deposit money into their U.S. account. These Wire Transfers are not specifically to fund the account for payroll; however, this account is debited by the Payroll Processor for purposes of funding the payroll. Would the transactions originated by the Payroll Processor on behalf of the Company have to be in the IAT format? No, these would be domestic payments. The funding to trigger the definition of the IAT has to be specific to fund the ACH transactions. 19. If the Receiver is located outside of the US that does not necessarily make an entry an IAT, but does it make sense that, to err on the side caution, Originators should create IAT entries for custo
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- If a US Company originates payments via the US ACH Network to US Receivers, but informs the ODFI that they will be receiving a transfer from a foreign account to fund the payments, is this an IAT?
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