We finished our SEPA pilot in December and it was a success. This was just before the postponement announcement in January 2014, we were so close it made sense to carry on and go live.
Our DD instructions were accepted by our banking partner, and by client banks after the waiting period, and the cash arrived on our statements. This was across multiple countries and bank accounts.
So here are a few things I learned from the SEPA project:
…can be interpreted any number of ways. It’s up to each client, and their compliance departments, to define compliance with a regulation. Take for instance pre-notification, you could consider a separate custom designed letter as a requirement for meeting the regulation. Or you could consider leveraging an existing communication with your customer as pre-notification.
While talking about pre-notification, there are country-specific variations in certain countries so some design logic was required to choose the correct path.
Banking Master Data is a major part of SEPA compliance. IBAN and BIC need to be present for each customer so this could be a huge exercise depending on volumes. There are some market vendors providing different solutions to resolve this, for instance you can generate an IBAN from the bank account and BIC using some solutions.
How many countries and bank accounts are in scope can be difficult to decide. In a complex company this is not straightforward and could require quite some work in conjunction with your banking partner. You can examine historical transaction volumes and take a position from there.
Our banking partner was also learning about SEPA but were very co-operative during the project phases. The specs were pretty good and formed a good basis for design of our custom programs. We designed a low-spec tech solution rather than complete automated compliance due to time restrictions.
In relation to mandate storage we designed a custom form to hold mandates and partial automation once the DD instructions were transmitted. Mandate Status(First, Recurring, Last) needs to be transmitted with each DD instruction as this is validated by some, but not all, client banks. Signed Date is also validated by client banks.
There is such a thing as too much testing! We tested every bank account in every country and it turned up very few bugs or information we didn’t know from the specs.We couldn’t involve client banks in the testing phase but there has not been material fall-out as most of the instructions were accepted. There are very few country-specific variations between the instrument specifications but a few to watch out for.
A BIC is a BIC is a BIC? Actually no, different types of BIC exist and will eventually route you to the same location. Your banking partner can assist here.
Banking Instruments are not all the same and vary widely in cost, since you are opening the code, can you use a more cost-effective instrument? Your banking partner and business teams should be involved to make sure this opportunity is taken.
This was a complex cutover requiring changes to code, configuration, program scheduling and close co-ordination between my client and our banking partners. We used a Low-volume start Up period while we waited for the initial instructions to be honored by the client banks. Wait until the cash is received after the cooling off period before moving into full volume processing.
We are still in post go-live period. We will watch the first 4 weeks transmissions closely, and then handover to normal support from there.
Use of the SEPA mark is under licence from the European Payments Council AISBL