Dodd-Frank Payments

The Dodd-Frank Act requires all consumer cross-border payments originating from the US to undergo certain oversight and controls. These controls are built into the API to ensure customers can provide the appropriate regulatory disclosures and capabilities required to meet Dodd-Frank compliance.

A Dodd-Frank payment is one that meets the following criteria:

  • The originating funds are held by a US financial institution (either direct customer or originating financial institution)
  • The customer or third-party remitter initiating the payment is either an individual type, or sole proprietor type making payments for personal, family, or household expenses.
    • To accurately determine Dodd-Frank eligibility, the partner or customer will be ultimately responsible for determining the Purpose of Payment. Sole Proprietor payments will only be considered Dodd-Frank if the partner passes in the isDoddFrank flag as true.
  • The funds are leaving the United States
  • The payment method is either ACH or wire, and can be any currency

If these conditions are met, or if the isDoddFrank flag is passed in the payment payload as true, the API will treat the payment as a Dodd-Frank payment, and the following conditions apply:

  • Each Dodd-Frank payment must be processed in its own batch
    • A batch containing a Dodd-Frank payment may not contain more than 1 payment
    • An existing batch with a non-Dodd-Frank payment may not accept any Dodd-Frank payments
  • Upon commit of the payment (either decoupled payment commit action or coupled batch commit), the payment will enter a “hold” state where the payment is able to be cancelled for up to 35 minutes
  • Once the 35-minute time limit has elapsed, the payment will enter the standard payment processing workflow.

To submit a Dodd-Frank payment, you can follow the workflow below:

  1. Create a new batch.
  2. Submit a Dodd-Frank payment by either:
    1. Creating a payment that meets the criteria above, or
    2. Creating a payment and specifying isDoddFrank = true in the payload.
  3. Quote and commit the batch.
  4. Query the Disclosure endpoint for required regulatory details.
  5. Retrieve cancelUntil information through payment status or webhooks.
    To cancel a Dodd-Frank payment:
    1. Submit a DELETE Payment request within the time allotted bycancelUntil (35 minutes from payment commit).