Proof of Authorization (POA) audits for collections customers: Payliance performs an audit for the first 5 days of processing, and then it lessens to a monthly audit for 3 months. After that, it is only quarterly.
Payliance will pull random transactions (multiple) and ask for the Proof of Authorization documents. Basically, they want to make sure that the authorization and revocation language are there, and that the date and amount that was debited is within scope of what was authorized. They want to make sure the POA is what was approved in Underwriting and using the correct SEC codes. POA requests are sent via email to the PDCflow Customer Success team with the transactions details (name, routing, amt, etc); Payliance will ask for a 2 day turnaround on the POA.
Here are the various types and the proof of authorization requirements that are required for each per NACHA regulations:
TEL-one time payment processed while on the phone with the consumer. Proof of Authorization Requirements: Voice Recording/Call Recording OR Email notification. (If the client enters an email address when taking the payment over the phone, PDCflow automatically sends the Notice Prior to Debit on behalf of the client).
WEB-A One Time ACH processed via a Website, requires input that validates identity, permission to debit and Revocation language.
Payliance already has screenshots of our Online Payment Portal. However, they will request to see the receipt for the consumer when a POA request is sent.
Sample Revocation language:
I understand that this authorization will remain in full force and effect until I notify COMPANY [insert manner of revocation, i.e., in writing, by phone, location, address, etc.] that I wish to revoke this authorization. I understand that COMPANY requires at least [X days/weeks] prior notice in order to cancel this authorization.
CCD- A One Time or Recurring Business to Business ACH transaction, requires Written Authorization or "wet" signature.
Payliance Audit Schedule:
PHASE 1 - New Merchant:
ACH: 5 pulls (or 100% if volume less than 5)
RCC: 6 pulls (or 100% if volume less than 6)
Duration: First 5 days of processing
PHASE 2 - Ongoing Monthly:
ACH: 4 pulls
RCC: 5 pulls
Duration: 3 consecutive months after Phase 1
PHASE 3 - Ongoing Quarterly:
ACH: 6 pulls
RCC: 8 pulls
Duration: Every quarter for duration of processing after Phase 2
Note: Internal audits are different than Bank requested POAs - Bank audits come in directly from the banks, those come in one at a time and intermittently depending on the merchant.