Attestations
What software do we use to send attestations for DD reviews?
*Extra credit - what is the full software system?
RSAM
*Extra credit - Relational Security Access Management
Do incentive reviews require draft agreements?
Yes, except PULSE
How many days does the participant have to complete and send back the attestation/supporting documents?
30 days
Who reviews incentive reviews?
Extra credit - be specific (ex: outside us, over $1M, etc)
AML and ABAC
Extra credit - AML reviews all; ABAC reviews outside US and over $1M
What is our Zip action SLA?
2-3 days
Are all new participants required to complete an attestation?
Yes
What websites do we use to check evidence of existence for PULSE FI Participants
FFIEC for Banks and Credit Unions
FDIC for Banks
NCUA for Credit Unions
How often do we review partners on a periodic basis?
*Extra credit - what is the risk rating based off of
12 months = high
24 months = moderate
36 months = low
*Extra credit - AML score
What does AML/ABAC look for in draft incentive agreements?
1. name/address
2. dollar amount
3. payment milestones/structure - how is it paid out
How long are DD approvals valid for?
12 months/1 year
What are the three attestations that may be sent to a PULSE processor request?
*Extra credit - what factors do you consider when determining which attestation to use?
Processor, Acquirer, and Issuer*
*Extra credit opportunity - KYC, direct/indirect, and acquirer/issuer processor
Name 4 out of 8 ad hoc DD requests
1. ownership change
2. name/address change
3. acquirer ID change
4. Termination
5. Wind-down
6. NPA Renewal
7. Custom Contract/Contract Review
8. Territory Expansion
What type of Participants do we conduct Partner Information Reviews on?
Category 5, 6, 7 Moderate partners & Category 4 Moderate/High partners
What are the five categories of High Brand Risk?
1. Non-Face-to-face Adult Content
2. Digital Currency
3. Gaming and Lotteries (US Only)
4. Skill-Game
5. Cannabis Sales (Canada Only)
What type of mitigation stops you from approving in Zip if the mitigation is not complete?
Pre-Contract
What's the difference between domestic and international participants when it comes to determining when attestations are required?
Incentives for international participants require an attestation if they are a new participant or existing participant not current on their PR.
Incentives for domestic participants do NOT require an attestation if they are new or existing.
What tabs do we update before submitting for approval and what do we update in each tab?
Due Diligence Tab
- Tier: N/A
- Overall Score: AML score
- Approval Type: Qualified/Collateral or Unqualified/No Collateral
Decision Tab
- Decision State: Approval Requested
- Approval Type: Qualified/Collateral or Unqualified/No Collateral
What information do we include in the PR Opportunity Note?
1. Participant Name
2. Private or Public
3. Country
4. Contract Summary which includes the type of agreement, contract #, execution date, initial term, renewal/termination dates, and what it allows the participant to do.
5. Operating Regulations
6. Customer Types
7. PEP
8. SOE
9. Initial questions/concerns due by date (5 business days)
10. Last completed PR review
11. How many months the participant is reviewed
12. Due date of current PR
13. Documents attached
Name all 8 internal contacts we insert for our reviews.
*Extra credit - name the two other SMEs that are in eCredit.
1. Shenika Davis (ABAC)
2. Lisa Pomeroy (BCP)
3. Garrett James (Data Security)
4. Lois Spiert (Disputes)
5. Amber Canedo (PULSE)
6. Evelyn Retkofsky (Theft and Fraud for EMEA and APAC)
7. Julian Moorer (Theft and Fraud for LATAM and Americas)
8. Crystal Guevara (Transaction Monitoring)
*Extra credit - AML and Counterparty
What happens if the agreement uploaded in Zip has a different dollar amount than what was originally due diligenced?
DD amount higher than agreement - clarify in Zip approval email and no additional review is required.
DD amount lower than agreement
Domestic - No new DD required, increase in $ should be captured in a note on the original DD transaction in eCredit
International - New DD required, start new review in eCredit following DD job aid
What Attestations have Global ATM questions?
1. DD Global ATM
2. PR Acquirer
3. PR Franchise
4. PR Global ATM
5. PR Network Partners
Who are the admin/account executive/chief of staff for each region?
Hint: we send PEP/SOE notifications to them
APAC: Servina Chan
EMEA: Joyce Kalema
LATAM: Rozina Bahadur
NA: Maureen Tynan
What is the full Decision State flow?
1. Processing
2. Engage RM
3. RM Engaged
4. Send Initial Correspondence
5. Initial Correspondence Sent
6. Send Questionnaire
7. Questionnaire Sent
8. Awaiting Questionnaire
9. Questionnaire Complete
10. Conduct Periodic Review
11. Pending Questions (if applicable)
12. Questions Answer (if applicable)
13. Approval Requested
14. Approved
15. Send Completion Correspondence
16. Completion Correspondence Sent
17. Periodic Review Complete
Name all individuals under Jeremy Samuels.
1. Angela Nixon
2. Maria Hatzopoulos
3. Alexandra Afryl
4. Cheryl Kinzly
5. Robin Petty
6. Bennette Domingo
7. Fredo Martin
8. Valerie McCafferty
9. Charisse Archie
10. Monica Paterra
11. Stephanie Brown
12. Eunice Hernandez
13. Rhonda Cherry
Name at least five workflow requests that do NOT go down our path.
1. Non-Disclosure Agreements
2. Discover Third Party Test Lab Accreditation Agreements
3. Advanced Payments Participant Program Enrollment Agreements
4. Meeting and Events Requests
5. New Purchase Order Only
6. Contract Update - Regulatory Change (Admin Only)
7. Mergers, Acquisitions, and Supplier Name Changes
8. MSA Lookback (Admin Only)
9. Notification Live Testing
10. Third Party Request
11. Terminate/Deactivate an Engagement or Agreement
*The only workflow requests that go down our path are Payment Services Partner/Product Requests