Pub. 11 2016-2017 Issue 6

March/April 2017 13 Extraordinary Service for Extraordinary Members. 800-373-3000 | finsales@dbe.bz | www.databusinessequipment.com Call DBE for a quote today! Glory QuickChange The Self-Service Coin Sorter customers and tellers prefer. Features Include: User Friendly Intuitive Screen Branding On-Screen Messaging Automatic Debris Removal Low-Staff Operational Impact l l l l l l DBE_MarApr17 QC_NBA_DBE_MarApr17_NBA 2/21/2017 9:57 AM Page 1 600 percent, with hold times that lasted hours. Unfortu- nately, UniRush had even more post-conversion problems. It failed to credit 45,000 direct deposits for two days and failed to correctly process another 900 direct deposits in the following weeks. UniRush double-posted 10,000 ACH deposits over a four-day period and failed to apply certain ACH debit transactions for three weeks. This resulted in negative balances. UniRush then took offsets against sub- sequent value loads without notice. For two weeks after conversion, UniRush failed to process certain cash loads to its cards and disabled certain card-to-card transfers. Thousands of customers were impacted. Customers did not receive timely direct deposits, received inaccurately inflated balance information, did not have access to their funds, and were subjected to conversion-caused negative balances. The impact on many unbanked paycheck-to- paycheck customers was serious. What Can We Learn? Don’t Do That Don’t botch conversions—that’s helpful advice, isn’t it? Maybe not, since banks already have plenty of reasons to be careful and thorough when they are executing a technology project. Nonetheless, given their central role in this case, sufficiency of a bank’s testing protocols may be ripe for an updated evaluation. Failure to test sufficiently and thoroughly before a technology implementation may constitute a violation of federal law. Going forward, MasterCard is expected to take steps designed to ensure that its platform and services and post- conversion outcomes are “in line” with expectations and outcomes agreed upon with its customers. MasterCard also is required to document its test methodology and to prevent service disruptions. A little more concrete are the require- ments: (i) to ensure that test environments accurately simulate results and processing times for transmission and uploading of “all” data files, for database reorganiza- tion and for daily processing during conversion; and (ii) to validate “all” conversion files for compatibility with the processor platform. When it agrees to a payment processor conversion, UniRush is expected to engage an independent third party acceptable to the CFPB to audit conversion preparation, implementation, and contingency planning. Audit results must be provided to the CFPB 120 days before the conversion, among other things. Banks facing a conversion should plan for the worst. Will the bank be able to properly manage the conse- quences when an implementation goes wrong? Technical glitches are a fact of life and perfection is probably not a ■ Counselor’s Corner — continued on page 14