The Clearing House (TCH) has introduced a new framework for all OBO payments, which are defined as RTP®, where a sender initiates the payment on behalf of a different person. These updated rules will supersede the previous requirements, specifically for Payment Service Providers (PSPs) and establish a unified approach for all OBO transactions.
Key Changes to Note:
- New OBO Framework for All: The distinction between PSPs and other entities initiating OBO payments is being removed. All participants sending payments on behalf of another party will now operate under the same set of Rules.
- Payment Transparency Obligations: Importantly, the new Rules also introduce payment transparency obligations for all Sending Participants, regardless of whether the payment is an OBO transaction or not. This implies a broader impact on your RTP® operations beyond just OBO payments.
Effective and Mandatory Compliance Dates:
Please mark these critical dates in your calendars:
- Effective Date: The new version of the RTP® Operating Rules is effective June 16, 2025.
- Mandatory Compliance Date: All Participants must fully comply with the new OBO rules by April 16, 2026.
PSP Transition Period: Important Considerations
The new rules include a transition period specifically for Payment Service Providers:
- Non-Approved PSPs (by June 16, 2025): If your institution meets the definition of a PSP but has not been formally approved by TCH as such by June 16, 2025, you must comply with the new OBO rules starting on the effective date (June 16, 2025).
- TCH-Approved PSPs (by June 16, 2025): If your institution is already approved by TCH as a PSP by June 16, 2025, you have the option to continue adhering to the previous PSP framework until the mandatory compliance date of April 16, 2026.
What You Need to Do:
- Review the Updated Rules: We strongly encourage you and your teams to thoroughly review the attached summary of the rule changes and the new version of the RTP® Operating Rules. These documents are also readily available in the Rules section of the RTP® Document Library on the TCH Public Site.
- Assess Your Current Processes: Evaluate your existing RTP® payment processes, particularly those involving third-party senders, to identify the necessary adjustments for compliance.
- Plan for Implementation: Develop a comprehensive plan to ensure your systems and procedures align with the new OBO Rules and the broader payment transparency obligations by the mandatory compliance date.
- Stay Informed: TCH will be scheduling an educational session to provide further clarity on these rule changes. We encourage your participation to gain a deeper understanding and address any questions you may have. Now might also be a good time to take a closer look at your institution’s policies and procedures, we offer RTP® compliance assessments, and you can always reach out for a no-obligation quote if you’d like some support.
The transition to this new OBO framework is a significant development in the RTP® ecosystem. Early preparation and a thorough understanding of these changes are essential to ensure a smooth and compliant transition for your institution.
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