European Payments Council SEPA Direct Debit Rulebook Changes

With effect from the 20th November 2016 as per the European Payments Council SEPA Direct Debit Core Rulebook V9.0 there are a number of changes to SEPA Direct Debits which will impact the way Originators submit Direct Debit files to AIB for processing. 

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    Shorter Collection Timelines

    As of the effective date of 20th November 2016 of the SEPA Direct Debit Core Rulebook version 9.0, all collections presented for the first time, on a recurrent basis or as an once- off collection can be presented to AIB up to two interbank business day prior to the due date {D-2}. The new cut-off time for submitting files to AIB will be 4 PM Irish Standard Time up to D-2 for all the collection types (FRST/RCUR/OOFF/FNAL). Originators can continue to use the currently applicable SDD Core collection presentation timelines {D-6/D-3} after 20th November 2016.

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    Transaction Type Changes

    The SEPA Direct Debit Rulebook currently require that the first collections sent by the Originators in a series of recurrent collections to their banks specifies the transaction type as a FRST. Effective 20th November 2016 it is optional to use Transaction Type FRST when submitting a first collection in a series of recurrent Direct Debit collections. Originators will now be able to submit a FRST collection for a Direct Debit as a RCUR Transaction type. Transaction Type FRST if used in a collection will be processed the same way as a RCUR Collection. Originators can continue using FRST as they do currently if they wish.

     

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    File Format changes (Mandatory for customers currently using SMNDA in Mandate Amendment information).

    Currently whenever a Debtor changes its bank account from one bank to another, Creditor is required to report amendment for this scenarios using SMNDA value in XML file. Post IBAN only regulation, the debtor might just provide the IBAN and not provide the BIC to the Creditor when changing bank account on a mandate. As the amended mandate may not indicate the BIC anymore, the Creditor will not always be able to identify whether or not the Debtor Bank has changed. To ease the impact of this regulatory requirement for the Creditor, the current requirement for the notification of a mandate amendment as part of the SEPA Direct Debit collection has been simplified. The code SMNDA currently defined as ‘Same Mandate with New Debtor Agent’ will be defined as ‘Same Mandate with New Debtor Account’ from Nov 2016. Creditors can now submit collections with SMNDA in Original Debtor Account field, whenever a customer changes IBAN (same bank or different bank).  They do not need to check if the account change happened in same or different bank. Customers who are using SMNDA currently and Customers who plan to use SMNDA as per new definition will have to make changes to their systems to support the new file formats.

    Below are the new File Formats:

    SDD Bulk Payments XML File Format

    SEPA Direct Debit Amendments

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    Switch over to new file formats

    • Customers who currently use SMNDA with Sequence Type FRST, should only submit transactions with Due Date up-to 28th Nov 2016 as per the old SMNDA definition and file formats to AIB until 18th Nov 2016. 
    • Any transactions submitted until 18th Nov 2016 with Due Date of 29th Nov 2016 or later and having transactions in old SMNDA definition and file format will be rejected by AIB.
    • Customers can submit files with transactions as per the new SMNDA definition from 20th Nov 2016 when new file formats become effective.
    • Any files having transactions with Old SMNDA definition submitted post 20th Nov 2016 would be entirely rejected by AIB.

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    FAQs

    1) Will there be any impact on re-conciliation if Originators starts using the shorter submission timelines?

    - No. There would not be any change in the way re-conciliation works currently. However if you opt for the shorter submission timelines of D-2, the window in which rejections are received will be shortened.

    2) What will be the impact of submitting transactions in old SMNDA definition after go-live?

    - AIB will be rejecting any files with any transactions submitted in old SMNDA format post Go-Live date. Customers should submit files as per the new file formats post go live.

    3) What kind of testing support would be provided by AIB to Originators who would be going ahead with the changes?

    - Please submit your test files to sepa.testfile@aib.ie or alternatively contact iBB Customer Support Team 0818 72 00 00.

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