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Hurricane Season Reminder on Business Continuity and Excused Delay

All of us at ePay send our best wishes for the safety of our members, partners, and staff in the path of Hurricane Ian. For financial institutions that may have their payments operations impacted, we want to remind you that the Excused Delay provision of the Nacha Operating Rules, found on page OR 3, Section 1.5, is intended to apply to processing delays caused by an interruption of communications or computer facilities that is out of the control of the financial institution, due to weather emergencies (“acts of God”) or war. This rule is not intended to excuse delays due to general failure of a financial institution’s or processor’s computer system or other equipment, which should be addressed in a contingency plan.  However, it is important to note that financial institutions in geographic areas where extreme weather conditions are a routine seasonal occurrence should have business continuity plans that address those conditions and should not rely on the Excused Delay rule. Click the link below for complete details on the proper usage of the Excused Delay rule in our Connections Member Community blog.