Upcoming Change to Disputability Rules

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We are excited to share important news that will bring about positive change to all participants in the DebiCheck Payment Stream. The implementation of this change should significantly improve your overall collection success.

Since the inception of DebiCheck, Amplifin has recognised that disputes will become a growing concern within our clients’ businesses. As a result, in May 2021 our Managing Director, Riaan De Swardt, took a pivotal step by submitting a comprehensive white paper to the South African Reserve Bank. This document meticulously outlined crucial issues pertaining to Authenticated Collections, with a specific focus on the disputability of these collections. In August of the same year, we released an updated white paper, sharing the progress that was made on this transformative journey.

Now, more than two years later, we are pleased to witness that the concerns identified by Amplifin during the inception of DebiCheck, have gained recognition and are being actively addressed by both the SARB and PASA.

To this end, we would like to highlight an extract from the rule change that is scheduled to be implemented by the DebiCheck participating banks on 23 October 2023. In terms of this change, in addition to the current non-disputability rules, the following criteria would render a successful Payment Instruction non-disputable:

“the Date Adjustment Indicator is set to “Yes” (Allow Date Change in ALLPS-i) and the Action Date, from the Effective Date of the Date Adjustment Indicator in Annexure R, falls on either (i) a previous Business Day, or (ii) any Processing Date between the Collection Day (due to it being a non-Business Day) and the previous Business Day”

What does this change mean for you?

At the core, this change is designed to ensure that non-disputability remains unaffected when the date adjustment indicator is set to “Yes,” indicating that the payer has mandated a date adjustment, and the collection is aligned with the earliest business day preceding a weekend or public holiday.

Let us illustrate these points further with some examples:

  1. Friday or Saturday Collections by Client Request:

If your scheduled collection date happens to fall on a Sunday, you now have the flexibility to reschedule it to the preceding Saturday. This is particularly beneficial for Payers who have their salaries credited on Saturdays.

Where the salaries will be credited on the Friday, the same applies.

In both scenarios, if the Payer has authorised an Allow Date Change (“Yes” on the date adjustment indicator), your collection will not be disputable, even when presented on the Friday or Saturday rather than the initially specified collection date indicated in the mandate register, where the date now falls on a Sunday.

  1. Public Holiday Adjustments:

If a collection date falls on a public holiday, such as a Tuesday, you have the option to move the collection to the preceding (Monday). This adjustment is non-disputable, provided the Payer has mandated an Allow Date Change (“Yes” on the date adjustment indicator).

It’s crucial to note that business days, for these purposes, are defined as Monday to Friday, excluding public holidays.

Now that we have highlighted the changes, it is important to note what remains unchanged, namely:

Next Collection Day Adjustments:

If the bank does not process collections on a Sunday or public holiday, your collection may be moved to the next available business day, typically a Monday. Importantly, this rescheduling is NOT disputable.

Authenticated collection day:

If the day component of the action date matches the authenticated collection day of the mandate and the collection amount is less than or equal to the authenticated collection amount, then the collection will not be disputable if the collection was successful. It is important to note that this rule applies to the action date of the collection, regardless of the date on which a successful collection was made if the collection went into tracking.

Reduced collection amounts:

If the collection amount is less than or equal to the authenticated collection amount, the collection will not be disputable if the day component of the action date matches the authenticated collection day.

Arrears collections:

All arrears’ collections remain fully disputable, regardless of the action date or collection amount.

What is required from DebiCheck users?

To receive the benefit of the new rule change for collections made on or after the implementation date, DebiCheck users are required to ensure that their clients are made aware of the fact that the Date Adjustment Indicator (Allow Date Change in ALLPS-i) was authenticated with a value allowing date changes where applicable.

It is also required that your clients understand that this allows you to submit collections for payment at an earlier or later date than the authenticated collection day.

This needs to be in writing and should also contain the Payers name, the Contract reference, the Abbreviated Short Name of the DebiCheck user, as well as the user’s contact details.

All of this information is already contained in the mandate that ALLPS provides and needs to be signed by the payer. Additionally, when signed electronically and uploaded, it will be available for compliance verification.

Please note: This applies to mandates signed prior to the implementation of collections falling on or after 23 October 2023.

Important: A bank notice has been issued, confirming that commencing from the 23rd of October 2023, these changes will be implemented by all DebiCheck participating banks. While this date has been agreed upon by the relevant parties, we will ensure that you stay informed should there be any amendments to the implementation schedule.

While these changes are a significant leap forward, it is important to acknowledge that they do not cater to larger date adjustments that might be necessary, particularly during December, for example when payers are paid on the 25th but are now being paid on the 15th. This matter was also discussed in the white paper; however, it remains a work in progress.

Should you have any queries, please do not hesitate to contact our Support Centre on (012) 993 8383.

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