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Nacha & Payment Rules Search

Nacha operating rules answered in three cited sentences, with the R10 return deadline dated on the Federal Reserve calendar

Cited answers in seconds, and the actual deadline on a calendar, before a return is late.

See one case, screen by screen ↓
demo6sfrom an ACH specialist's question to an answer with all four claims checked against their passages
demo6banking daysleft to return the sample unauthorized debit, dated Monday, November 2 on a calendar that skips Federal Reserve holidays
demo4.1%of October's 652 sample questions routed to the Payments Compliance Officer, each with its reason and clock
target0answersgiven when two sources disagree or an edition is out of date; compliance gets both passages instead
In short

What is Nacha & Payment Rules Search?

Nacha & Payment Rules Search answers questions about the Nacha operating rules, Fedwire, FedNow, SWIFT and your own payments procedures in two or three plain sentences, each claim footnoted to the passage it rests on. Agents ask the one or two facts that change the answer, read them from the core banking system and the ACH processing platform, and date the deadline on a calendar that skips weekends and Federal Reserve holidays. When sources disagree, they refuse and route the question to your Payments Compliance Officer.

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Updated

The problem

Why a Nacha operating rules question still costs a day, and sometimes a return

A question about the Nacha operating rules rarely stays inside the Nacha rulebook. A member says a debit that settled seven weeks ago was never authorized: can the credit union still return it, and by when? The answer sits in the current Nacha edition, which changes every year and again mid-year, beside Regulation J, UCC Article 4A, the Fedwire and FedNow operating circulars, SWIFT's guidelines and the credit union's own payments procedures, each on its own edition. Staff ask a colleague or a payments association helpline, and count days on a desk calendar that may not show Federal Reserve holidays.

The cost shows up later. A day counted wrong becomes a late return the originating bank may refuse, and the loss stays with the credit union. A procedure that fell behind the rules becomes a late recall: a wire procedure still names a service message Fedwire retired when it moved to ISO 20022 in July 2025. And when the annual ACH rules compliance audit or the NCUA examiner asks what was answered, from which source, there is no record.

typical35.2billionACH payments in 2025, worth $93 trillion, every one under the Nacha operating rules
typical60calendar daysfrom settlement for an unauthorized consumer debit, then the return is due by the opening of the next banking day
typical6banking daysafter the signed statement is reviewed: the second R10 clock, in force since October 1, 2024
Where the minutes of one hard rule question goestimated
By hand55 minutes
With the solution4.1 minutes
  • Finding the right rulebook, and the edition in force on the settlement date15 → 0.1 min
  • Reading the passage and the credit union's own procedure10 → 1 min
  • Checking the account type and the settlement date in the core and the ACH platform5 → 0.5 min
  • Counting calendar and banking days around weekends and holidays10 → 0.5 min
  • Opening the return case and drafting the entry10 → 2 min
  • Writing down the answer and its source for the audit5 → 0 min

Estimated split for one question an ACH specialist is unsure of, by hand and with the solution. Waiting for a colleague or a helpline to call back is left out; by hand it often adds hours.

How it works

How one question is answered

Seven agents answer, cite and count the deadline; a checking agent refuses when sources disagree, and the Payments Compliance Officer approves every edition and change.

What comes in
What arrives4 sources · the question, the rulebooks, the procedures, the entry
Agents at work
Question agentredact, classify
Then
Answer agenteditions in force on the date
Calculation agentthe facts, banking days
Then
Checking agentevery claim to its passage
Then
Hand-off agentcase with the drafted return
Edition agentnew editions for approval
A person decides
The operator decides; a second specialist releases the returnthe Payments Compliance Officer approves editions and changes · nobody approves their own
What comes out
Cited answer
Dated deadline
Audit pack
One case, step by step

One unauthorized debit, from a question to a dated R10 return

Norrell Federal Credit Union, $6.8 billion and 520,000 members, on Thursday, October 22, 2026. About 120 payments and member services staff ask around 900 questions about the Nacha rules, Fedwire, FedNow, SWIFT and Norrell's procedures a month. At 10:41 AM, Keoni Brannigan in ACH operations has a member's dispute and a question he is not sure of.

  1. 0110:41 AM

    A question in his own words

    Keoni Brannigan · ACH Operations Specialist

    A member at the Fenmore branch told Sunniva Ochoa that a $386.40 PPD debit from Kestrel Vale Home Plans, which settled Monday, August 31, was never authorized. Sunniva handed it to ACH operations. Keoni types: "A member says a debit that settled August 31 was unauthorized. Can we still return it?" The question box shows the rulebooks in force before he asks.

  2. 026 seconds later

    Three sentences, every claim footnoted

    Question, answer and checking agents

    The question agent finds nothing personal to remove and classifies it Nacha, ACH returns, receiving bank. The answer agent searches the Nacha Operating Rules 2026 edition, Regulation E and Norrell's procedure ACH-RT-03. The checking agent matches all four claims to their passages, confirms every edition is in force on August 31, and scores 0.94.

    "Yes. A consumer can still have it returned as R10 (originator not known or not authorized) once she signs a Written Statement of Unauthorized Debit."

  3. 03One click

    The passage behind the chip

    Keoni Brannigan · ACH Operations Specialist

    Each claim carries a chip: Nacha 3.8, Nacha 3.12, App. 4, ACH-RT-03 §2.4. Keoni opens Nacha 3.8, timing of extended return entries. The words the answer rests on are highlighted, with the edition, the note that it is in force on the date asked, and who approved it for the agents: Imogen Thackeray, on January 9, 2026.

    "Approved Jan 9, 2026 by Imogen Thackeray · a summary of the licensed rule text"

  4. 04Your situation

    Two facts, read from the systems, and a date

    Calculation agent

    The agent asks only what changes the deadline, and pre-fills both: a consumer share draft account from the core banking system, and the August 31 settlement from the ACH processing platform. Day 60 is Friday, October 30, so the return must reach the originating bank by opening of business Monday, November 2. Today is day 52: 8 calendar days, 6 banking days left. If Keoni reviews the statement today, the statement clock ends at the opening of Friday, October 30.

    "Holidays in the window: Labor Day (Mon Sep 7), Columbus Day (Mon Oct 12)."

  5. 05Flip a fact

    A business account changes the answer

    Keoni Brannigan · ACH Operations Specialist

    To be sure, Keoni marks the account as business. The answer changes to R29, whose two-banking-day window closed on Wednesday, September 2. A late return by agreement, R31, is only for CCD and CTX entries, and this one is PPD. The core banking system says consumer, so the R10 answer stands.

  6. 0610:43 AM

    The return handed to ACH operations, with the deadline attached

    Keoni Brannigan · ACH Operations Specialist

    Keoni clicks Hand the R10 return to ACH operations. Case CM-26-04418 opens in case management with the statement sent to the member's digital banking for e-signature and the return entry drafted from the ACH processing platform. The member signs at 10:52 AM; Keoni reviews the statement, which starts the statement clock, and prepares the return.

  7. 07Released

    A second specialist releases it

    Ondine Petrakis · Senior ACH Operations Specialist

    Keoni cannot release a return he prepared. Ondine Petrakis releases it into the 4:00 PM ET return file, ahead of both limits. The member's Regulation E claim goes on to deposit operations.

    The agents drafted the entry. They never release a return, send a wire message or recredit a member.

  8. 08Earlier, 10:22 AM

    A wire recall question it would not answer

    Checking agent

    Dariela Yusupova in the wire room asked how to recall a $48,500 wire sent to the wrong account. Norrell's WIR-04 §6, version 9, reviewed March 2024, says to send a legacy-format service message; Fedwire's ISO 20022 formats, in force since July 14, 2025, use a camt.056 request, a camt.029 answer and a pacs.004 return. The checking agent refused the message step, showed both passages and what both agree on, and routed the question as RQ-0175 on a 30-minute wire clock.

    What is safe to do now: call the receiving bank's wire room and log it. Do not send a legacy-format message.

  9. 0910:41 AM

    Routed questions, ordered by their clocks

    Imogen Thackeray · Payments Compliance Officer

    Imogen's queue holds 6 questions, RQ-0175 first with 11 minutes left. Each says why it came to her: sources disagree, an edition out of date, the agents below the 0.85 confidence threshold, or a routing rule such as an unauthorized wire over $100,000, which escalated at 75% of its clock. A question touching a report to FinCEN shows only that it is restricted to the BSA Officer.

  10. 10Approved

    The procedure fixed, and the refused questions answered again

    Imogen Thackeray · Payments Compliance Officer

    Lachlan Wexley drafted CHG-26-014 on October 21: WIR-04 §6, version 10, with the camt.056, camt.029 and pacs.004 steps. The edition agent found what depends on it. Imogen reads the old version beside the new and approves; the 4 questions refused on §6 since October 19 are answered again, their askers told, and lesson L-42 for new wire staff is unblocked.

Who it’s for

Built for everyone who touches a payments rule.

The same morning, seen by the four people it passes through: what their day looked like, and what it looks like now.

KB
Keoni BranniganACH Operations Specialist · asks, reviews statements, prepares returns
ACH Operations Specialist
Before
Works about 30 returns, NOCs and member disputes a day; for the 4 or 5 that turn on a rule he is unsure of, he asks a colleague and counts the days on a desk calendar.
Now
Asks in his own words, opens the passage behind each claim, and gets the deadline dated on a banking-day calendar, then hands the return to ACH operations with one click.
DY
Dariela YusupovaWire Room Operator · Fedwire and SWIFT, against the 6:00 PM ET cutoff
Wire Room Operator
Before
Follows the wire procedure as written, even where it still names a message format the network retired.
Now
Is told when the procedure and the network rule disagree, before she sends anything, with the safe step to take now and a 30-minute clock on compliance.
IT
Imogen ThackerayPayments Compliance Officer · approves every edition, change and reusable answer
Payments Compliance Officer
Before
Rule questions reach her by phone and email with no shared record, and a stale procedure shows up only when a recall goes wrong.
Now
Gets only the questions that need her, each with its reason, draft and clock, and approves editions and procedure changes with the old text beside the new.
BH
Bram HollinsPayments Operations Manager · a team of 26, with 9 new this quarter
Payments Operations Manager
Before
Hears the same R10 or R11 question again and again, and no one sees the pattern.
Now
Sees what new staff ask repeatedly and approves lessons built from their real questions into the learning management system.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents answer, cite and count the deadline; a checking agent refuses when sources disagree, and the Payments Compliance Officer approves every edition and change.

Question agent

Reads the question, removes member names, account, card and phone numbers before it is saved, classifies the rail (ACH, Fedwire, FedNow, SWIFT or procedure), the credit union's role and the topic, and spots restricted topics.

  • Never saves member identifiers
  • Never answers a question about a report to FinCEN; it goes to the BSA Officer only
Answer agent

Searches the editions in force on the date that matters and the credit union's procedures, and writes two or three sentences in plain words, every claim footnoted to its passage.

  • Never cites a source that is not approved
  • Never answers from outside the library
  • Never gives legal advice
Calculation agent

Asks the one or two facts that change the deadline, pre-fills them from the core banking system and the ACH processing platform, counts calendar and banking days on the approved Federal Reserve holiday calendar, and layers the credit union's 4:00 PM ET file cutoff on top.

  • Never assumes a fact it could not read
  • Marks a date provisional when that year's holiday schedule is not yet approved
Checking agent

Matches every claim to its passage, checks each edition is in force on the date, compares procedure with rule and scores its confidence.

  • Refuses when sources disagree or an edition is out of date, and shows both passages
  • Between 0.70 and 0.85 routes the question to compliance with a draft; below 0.70 gives no answer
Hand-off agent

Opens the case in case management with the member's statement for e-signature, the return entry drafted in the ACH processing platform, and the deadline.

  • Drafts only: never releases a return
  • Never sends a wire message or recredits a member
Edition agent

Watches the issuers for new editions and amendments, loads them with their effective dates, compares old and new, and finds the answers, procedures and lessons that depend on a change.

  • Nothing it loads is used until the Payments Compliance Officer approves it
  • Answers refused questions again only after their fix is approved, and tells the askers
Training agent

Groups repeated questions, especially from staff in their first 90 days, and drafts four-minute lessons and quizzes from the questions they actually asked.

  • Never publishes a lesson; the Payments Operations Manager approves it
  • Holds a lesson that depends on an unapproved procedure change
Payments Compliance Officer

Approves every edition, procedure change and reusable answer; never their own. The agents propose; a named person decides.

Ask in plain words

Ask about any answer under the Nacha operating rules, or any deadline, edition or change

Ask in plain words, or say what to prepare. Every answer cites its passage, and the assistant opens the screen it is talking about.

Why R10 and not R11 for Keoni's member?

Because she says she never authorized Kestrel Vale Home Plans at all. R10 is for an originator the member does not know or never authorized; R11 is for a debit from a company she did authorize, but not as agreed, such as the wrong amount or date. Both need her signed statement, and both use the extended timeframe: by the opening of Monday, November 2, and within six banking days of reviewing her statement.

What changes when the wire recall procedure is approved?

CHG-26-014 replaces the retired legacy-format message in WIR-04 §6 with a camt.056 request, a camt.029 answer and a pacs.004 return. When Imogen Thackeray approves it, the 4 questions refused on §6 since October 19 are answered again and their askers told, RQ-0175 gets the corrected step, and lesson L-42 is unblocked. Lachlan Wexley drafted it, so he cannot approve it.

What are new ACH staff asking most?

The 9 people in their first 90 days asked 202 of October's 652 questions. The top repeat is R10 or R11: 23 times by 9 people this quarter. The training agent built lesson L-41 from those questions, with five quiz questions, for Bram Hollins to approve.

Prepare the pack for the annual Nacha audit

The pack for June 1 to October 22 holds 4,274 questions with their answers, sources, editions and confidence; the 175 routed questions and who answered them; every edition load and procedure change with maker and checker; every return released with its preparer and releaser; and overrides and flags with reason codes. Restricted questions stay out unless the BSA Officer adds them. The 2026 audit is due by December 31.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

An unauthorized ACH debit answered in three cited sentences, with the return deadline on a calendarThe signature screen: an ACH operations specialist asks in plain words whether a debit that settled August 31 can still be returned. Agents answer in two or three sentences, each claim footnoted with a chip that opens the Nacha Operating Rules passage or the credit union's own procedure, then ask the two facts that change the ACH return time frame and date it on a calendar that skips weekends and Federal Reserve holidays.
Every citation opens the exact rule passage, its edition and who approved itClicking a footnote chip opens the passage the answer relies on, with the words it rests on highlighted, the edition of the Nacha rules in force on the date that matters and the compliance approval.
The deadline counted day by day, with the Federal Reserve holidays it skippedDetails on demand: the calculation agent shows how it counted the 60 calendar days and the six-banking-day statement clock for the R10 return code, and which holidays fell in the window.
Change one fact and the answer changes: a business account means R29, and that window has closedThe facts are switches. When the specialist marks the account as business, the agents answer again under the R29 return code: two banking days, closed on September 2, and why a late return by agreement does not apply to this PPD entry.
The R10 return handed to ACH operations, prepared by one specialist and released by anotherFrom answer to action: one click opens a case with the member's written statement of unauthorized debit for e-signature and the return entry drafted from the ACH processing platform. One specialist reviews and prepares; a senior specialist who did not prepare it releases it. The agents never release a return.
When a procedure and the network rule disagree, the agents refuse and show both passagesA checking agent compares the credit union's wire procedure with the Fedwire rule in force. They disagree, so it refuses to give the message step, says what both sources agree on, shows the two passages side by side, lists what is safe to do now and routes the question to the Payments Compliance Officer on a 30-minute wire clock.
Questions for compliance, each with why it came, its clock and escalationAbout 4% of questions reach the Payments Compliance Officer: when sources disagree, an edition is out of date, the agents are below the confidence threshold, or a routing rule says so. Each carries its reason and a clock; restricted questions stay hidden.
A routed answer sent by the analyst and approved for reuse by a second personThe agents draft the answer with its sources; the analyst sends it to the asker and proposes it as an approved answer; only a different person, the Payments Compliance Officer, can approve it for the agents to reuse.
A procedure change shown old beside new, with its impact, its maker and its checkerThe fix for the refused wire question: the analyst's new version of the procedure, beside the old, with what changes when it is approved. Until the Payments Compliance Officer approves it, the agents keep refusing that step.
Every rulebook and procedure with its edition, effective date, approver and statusThe library the agents may answer from, from the Nacha Operating Rules and Guidelines 2026 edition to Regulation J, UCC Article 4A, Fedwire, FedNow and SWIFT. Nothing new is used until the Payments Compliance Officer approves it. A failed source refresh is shown, and the agents lower their confidence on that source until it refreshes.
Nine payment and dispute clocks on the Federal Reserve calendar, with provisional dates flaggedThe same calculation the agents use, on its own: pick a rule clock, enter the date, and see the deadline, the counting and the holidays skipped. Dates in a year whose holiday schedule is not yet approved are marked provisional.
Training built from the questions staff actually ask, for the manager to approveFor the Payments Operations Manager: a few clear numbers, what the agents found in the questions, lessons drafted from real questions for the learning management system, and the new staff who repeat questions.
The audit trail and an export pack for the annual Nacha audit and NCUA examinersWho did what, when, why and with which evidence, for every question, answer, edition, approval and release, and one pack for the ACH rules compliance audit or the examiner, with restricted questions held back unless the BSA Officer adds them.
Governance

Built for the Nacha audit and the examiner: cited, approved, on the record.

Only approved editions, in force on the dateThe agents answer only from rulebooks and procedures the Payments Compliance Officer has approved, each used from its effective date. A failed source refresh is shown, and the agents lower their confidence on that source until it refreshes.
Every claim cited to its passageEach sentence of an answer carries a chip that opens the passage, its edition and who approved it. The checking agent matches every claim before the answer is shown.
Refusal when the sources disagreeWhen a procedure contradicts the rule in force, or an edition is out of date, the agents give no answer. They show both passages, what both agree on and what is safe to do now, and route the question with a clock set by the payment's cutoff.
Maker-checker on what mattersA specialist prepares a return and a senior specialist releases it. The analyst loads an edition, drafts a procedure change or proposes an approved answer, the administrator proposes a settings change, and the Payments Compliance Officer approves each. Nobody approves or releases their own work.
Member data removed, reports kept confidentialMember names, account, card and phone numbers are removed before a question is saved, and account numbers are masked to the last four. A question about a report to FinCEN reaches the BSA Officer only and never appears on a member view or in the open log.
An audit trail auditors can exportWho did what, when, why and with which evidence, for every question, answer, edition, approval, override and release, with prompt and model versions. Packs export for the annual Nacha Rules Compliance Audit, NCUA examiners, internal audit and the Supervisory Committee.
Configuration

Your thresholds, your clocks, your calendar

What the credit union configures. The Systems Administrator proposes a change and the Payments Compliance Officer approves it before it takes effect.

SettingDefaultChoose from
Answer confidence threshold0.85A slider from 0.70 to 0.95; between 0.70 and the threshold the question goes to compliance with a draft, below 0.70 there is no answer
Editions the agents may useFrom the effective date, once approvedUse only from the effective date · use only after the Payments Compliance Officer approves · refuse when a procedure is older than a rule it depends on
Issuer source refreshDaily at 6:00 AM ETOn or off; lower confidence on a source whose refresh failed
Wire room questions30 minutes, before the 6:00 PM ET cutoffEscalate at 75% of the clock, to the officer's phone
ACH, member and other questions4 business hours · 1 business dayEscalate at 75% of the clock
Always routedUnauthorized wires over $100,000 · any question about a report to FinCENTo the Payments Compliance Officer · to the BSA Officer only
Calendar and cutoffsFederal Reserve holidays by year · return file 4:00 PM ET · wire 6:00 PM ETEach year's schedule approved before use; Saturday holidays not observed
RetentionSix years · BSA-related items five yearsQuestions, answers and sources for the Nacha audit · 31 CFR 1010.430 for BSA items
Connections

Works with the ACH rules and the systems payments staff already use

Rules and procedures libraryNacha Operating Rules 2026, Regulation J, UCC Article 4A, Fedwire and FedNow circulars, SWIFT CBPR+ and the credit union's procedures, by edition
ACH processing platformentry lookup and return drafts; nothing is released by the agents
Core banking systemaccount type and ownership, read only
Case management and document imagingreturn cases, call logs and signed statements
Digital banking e-signaturewritten statements of unauthorized debit, signed by the member
Learning management system and identity providerapproved lessons and quizzes; single sign-on and roles
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
6s
median from question to a cited answer
Todaya colleague or a helpline, often hours
With agents≈ 6 seconds
typical
60days
R10 limit dated on a calendar that skips weekends and Federal Reserve holidays
Day 52 today
Nacha Operating Rules
target
0answers
given when sources disagree or an edition is out of date; compliance gets both passages

“demo” = seen in the working solution, on its sample questions, returns and wires · “target” = the design goal, measured in the live solution · “estimated” = our estimate for one hard rule question at the demo credit union · “typical” = published figures and rules (Nacha, 2025 ACH Network volume: 35.2 billion payments worth $93 trillion; the Nacha Operating Rules on the extended return timeframe and the October 1, 2024 amendment on the statement clock; the Federal Reserve holiday schedule; Federal Reserve Financial Services on Fedwire's move to ISO 20022 on July 14, 2025; 31 CFR 1010.430 on BSA record retention). Rule passages in the working solution are summaries, because the Nacha rulebook text is licensed. People, the credit union, companies, banks and account references named on this page are fictional: characters and sample data in the working solution.

Questions

What payments operations and compliance teams ask about the Nacha operating rules.

What is Nacha & Payment Rules Search?

Nacha & Payment Rules Search answers questions about the Nacha operating rules, Fedwire, FedNow, SWIFT and your own payments procedures in two or three plain sentences, each claim footnoted to the passage it rests on. Agents ask the one or two facts that change the answer, read them from the core banking system and the ACH processing platform, and date the deadline on a calendar that skips weekends and Federal Reserve holidays. When sources disagree, they refuse and route the question to your Payments Compliance Officer.

How long does a credit union have to return an unauthorized ACH debit?

For a consumer account, an R10 or R11 return under the extended timeframe must reach the originating bank by opening of business on the banking day after the 60th calendar day from settlement. Since October 1, 2024 it must also arrive by the opening of the sixth banking day after you finish reviewing the member's signed statement. The calculation agent counts both clocks on the approved Federal Reserve holiday calendar, shows the counting day by day and puts your file cutoff on top; the earlier date wins.

What is the difference between the R10 and R11 return codes?

R10 is for a debit from an originator the member does not know or never authorized; R11 is for a debit from a company the member did authorize, but not as agreed, such as the wrong amount or date. Both need a signed written statement of unauthorized debit and use the extended timeframe. On a business account the answer changes: R29, with two banking days, and the agents say so when you switch the account type.

What happens when the Nacha rules and our own procedure disagree?

The checking agent refuses to answer the step in question. It shows the two passages side by side, says what both sources agree on and what is safe to do now, and routes the question to the Payments Compliance Officer with a clock set by the payment's cutoff, 30 minutes for the wire room. When a procedure change is approved, the questions refused on that section are answered again and their askers told.

Does it cover Fedwire, FedNow and SWIFT rules as well as the ACH rules?

Yes. The library holds the Nacha Operating Rules 2026 edition with its March and June 2026 amendments, Regulation J, UCC Article 4A, Regulation E, the Fedwire operating circular and ISO 20022 formats, the FedNow operating procedures, SWIFT CBPR+ usage guidelines and your own procedures. Each source has its edition, effective date, approver and status, and an answer uses only the editions in force on the date that matters.

Does it help with the annual ACH rules compliance audit?

It keeps the record the audit asks for. Every question, answer, source, edition, confidence score, routing, override and released return is on the audit trail with who, when, why and the evidence, kept six years, and BSA-related items five. One click builds an export pack for the annual Nacha Rules Compliance Audit, NCUA examiners, internal audit or the Supervisory Committee; restricted questions stay out unless the BSA Officer adds them.

Do people stay in control?

Yes. The agents read, cite, count, draft and refuse; they never release a return, send a wire message or a notice, recredit a member or approve anything. A senior specialist releases returns someone else prepared, and the Payments Compliance Officer approves every edition, procedure change, reusable answer and setting. Overrides carry a reason code, from O1 rule misread to O4 newer guidance.

How does it go live at our credit union or bank?

The Agentic Solution Engine builds and deploys it from your requirements and your documents: your procedures, your cutoffs, your approvers, routing clocks and roles, connected to your ACH processing platform, core banking system and case management. It goes live once every quality gate has passed.

See it on
your returns and wires.

We'll run Nacha & Payment Rules Search on your own procedures and the rule questions your payments staff ask.