Send us a text. (email us if you need a response)

EPISODE SUMMARY:

QUESTIONS ALWAYS WELCOME. jcasali@neach.org

In this episode of Wrestling Payments, host Joseph Casali continues his three-part NACHA SmackDown series, taking listeners inside the high-stakes world of ACH rules violations. Through compelling real-world cases, Joseph reveals the consequences when financial institutions fail to follow proper authorization procedures.

The episode examines Steward Bank's repeated failures to provide valid authorization proof, resulting in escalating fines from warnings to $7,500. Joseph also explores O'Leary Bank's improper SEC code use, demonstrating critical compliance errors that payment professionals must avoid.

"These are really places to learn how the rules apply," Joseph explains. "Look what happened here. This went wrong, and they got fined for it. It's a really good way to learn how the rules work."

While emphasizing that NACHA's enforcement process doesn't recover funds for affected parties, Joseph provides valuable insights for operations managers and directors responsible for ACH compliance.

KEY INSIGHTS:
The Enforcement Process Protects the Network, Not Individual Cases
NACHA's enforcement process exists to uphold system integrity, not recover funds for affected parties. The process identifies rule-breakers and imposes fines to discourage future violations, but consumers must look elsewhere for recovery. Understanding this distinction is crucial for banking professionals managing payment operations—rules enforcement serves as a deterrent while arbitration offers a path for financial recovery. This separation of powers helps maintain ACH Network quality while giving institutions multiple ways to address unauthorized transactions.

Authorization Type Must Match the SEC Code
SEC codes must align with the authorization type obtained from customers—a critical compliance point for operations managers. Converting a check into a WEB debit constitutes an automatic rules violation because the authorization types differ fundamentally. Payment professionals must understand that each SEC code requires its distinct authorization format. This knowledge helps institutions avoid costly violations while ensuring proper payment processing across different channels.

Progressive Enforcement Drives Compliance
NACHA's enforcement panel uses progressively increasing penalties to encourage compliance, starting with warnings before moving to monetary fines. For payment professionals, this highlights the importance of addressing issues immediately rather than ignoring them.

The panel's willingness to impose recurring monthly fines for persistent violators underscores NACHA's commitment to maintaining network integrity.

Proper Documentation Prevents Costly Violations
Under NACHA rules, the obligation to provide valid proof of authorization within 10 banking days is non-negotiable. Financial institutions must maintain organized, accessible records and ensure staff understand how to respond properly to authorization requests.

Both cases highlight the importance of having knowledgeable staff (ideally AAP-certified) who can identify proper authorization formats and requirements. Operations managers should implement procedures ensuring authorization documentation matches receiver information exactly, as mismatches invalidate the proof and trigger violations.

Send us a text. (email us if you need a response)

In this episode of Wrestling Payments, Joseph Casali launches a three-part "SmackDown Rules Violations in the Ring" series, examining ACH rule violations through wrestling metaphors. He analyzes two critical NACHA case studies that payment professionals should understand to avoid costly compliance mistakes.

The first case involves Glenn Transportation's unauthorized $50,000 reversal attempt against KJN Storage, earning them a warning letter as a first-time offender. The second, more severe case examines a complex arrangement between Macklan Development, Workforce Assist, and Processing for You Inc., where improper payroll reversals led to a substantial $100,000 fine.

Joseph details how the third-party payment processor initiated unauthorized reversals when their customer failed to fund payroll credits, causing consumer accounts to be debited multiple times. This "nested third-party" arrangement lacked proper oversight and controls, resulting in widespread harm to employees, businesses, and financial institutions.

"Just like in wrestling, when you try to reverse the outcome after the match is over, you'll find yourself facing the regulatory referee," warns Casali. "In the NACHA ring, proper reversals require proper cause, not just a desire to take back what you've already given."

Prevention Beats Correction in Payment Operations
The root of most improper reversals isn't misunderstanding rules—it's inadequate front-end controls. Rather than focusing on when reversals are permitted, payment professionals should strengthen transaction validation before payments enter the network. Organizations eliminate the scenarios that tempt improper reversals by implementing proper authorization checks, sufficient funding verification, and receiver confirmation processes up front.

Prevention not only avoids NACHA enforcement but creates more efficient operations overall. Smart payment managers know that building guardrails before transactions occur costs far less than attempting corrections after funds have moved.

Clear Accountability Is Essential in Third-Party Relationships
When payment services involve multiple providers, responsibility becomes dangerously diluted. The "nested third-party" arrangement in the payroll case demonstrates how quickly problems cascade when accountability chains break down. Financial institutions must establish explicit contractual requirements defining precisely who bears responsibility for compliance at each processing stage.

Regular audits, performance monitoring, and transparent communication channels between all parties are essential. The most successful payment operations leaders create relationship maps that establish clear lines of authority and ensure visibility across the entire transaction lifecycle.

Consumer Impact Elevates Regulatory Response
What regulators might treat as minor procedural issues in B2B contexts become major enforcement priorities when consumers feel the impact. Payment operations teams need separate, enhanced control frameworks for transactions touching consumer accounts. Payroll processing, direct debits, and other consumer activities demand heightened verification steps, stronger reconciliation processes, and faster exception handling.

The immediate financial hardship consumers experience from improper transactions—and the resulting reputational damage—justifies investing in these stronger safeguards. Smart operations leaders recognize this regulatory reality and allocate resources accordingly.

Send us a text

EPISODE SUMMARY

In this episode of Wrestling Payments, host Joseph Casali draws surprising parallels between professional wrestling and the evolution of payment systems. After watching WrestleMania 41, he experienced an "aha moment" recognizing that successful payment transformations follow the same narrative structure as compelling wrestling storylines.

The episode explores Donald Miller's StoryBrand framework, breaking down how every story, including payment innovations like check conversion to ACH and the digital transformation journey, features a character who faces challenges and needs guidance to achieve success. From the National Automated Clearinghouse Association (NACHA)'s early rules for check conversion to today's AI and crypto developments, each payment evolution represents its own hero's journey.

Listeners are challenged to identify their role in the payment industry narrative: Are you the hero navigating change, or the guide helping others transform? The host suggests that recognizing your place in the story can help financial professionals better navigate the continuous evolution of payment systems and build meaningful payment stories.

KEY INSIGHTS

Every Industry Evolution Follows a Classic Story Structure
The payment industry's evolution, from paper checks to digital transformation, follows the same narrative arc as classic storytelling. Just as Donald Miller's StoryBrand framework outlines, payment innovations begin with a character (organization) facing a problem (inefficient processes), meeting a guide (industry experts or associations like NACHA), receiving a plan (new technology or methodology), and taking action that leads to success or avoids failure. Viewing payment evolution through this lens gives professionals a framework to anticipate challenges and recognize their role in the larger industry story.

Identifying Whether You're a Hero or Guide Changes Your Strategy
Your role in the payment industry story—hero navigating challenges or guide helping others succeed—fundamentally changes your approach to innovation and problem-solving. Heroes face obstacles directly, implement solutions, and undergo transformation. Guides offer wisdom and experience to help others navigate challenges. Many payment professionals mistakenly position themselves as heroes when they could create more impact as guides. Being a guide—like Yoda in Star Wars—often creates more lasting impact than heroic action, especially for those with extensive industry experience who can mentor others through digital transformation or regulatory changes.

Success Stories in Payments Are Never-Ending Narratives
Payment innovation represents a continuous narrative where each success leads to the next challenge, unlike traditional stories with definitive endings. Innovations like check digitization and ACH systems solved immediate problems but created new storylines and challenges. Completing one transformation doesn't provide a permanent "happy ending" but instead opens the next chapter. This perpetual evolution requires viewing projects as episodes in an ongoing industry saga. Embracing this never-ending narrative perspective helps maintain adaptability, avoid complacency after successes, and stay prepared for constant changes driven by technology, regulations, or market demands.

Recognizing When You're the Guide, Not the Hero [00:15:40]
"If you look around the room and you don't see the person who's doing this, you are that person. Maybe you're a guide. Maybe you're a guide in the story. And that's not a negative. You're Yoda. How can you get better than Yoda? You are Paul Heyman in wrestling, you are the guide. You're the advisor, the wise man."

Send us a text

EPISODE SUMMARY

In this episode of Wrestling Payments, host Joe Casali sits down with Travis Dulaney, CEO and Co-founder of BalancedTrust, to unpack the ongoing friction between fintech startups and their bank partners. From missing compliance standards to misunderstandings around regulatory risk, Travis explains why so many good ideas hit a wall.

Travis shares lessons from his time launching and selling PayFi, where inconsistent feedback from sponsor banks highlighted a significant problem: no standard process for compliance approval. That frustration led to the birth of BalancedTrust, a platform helping fintechs and banks align risk tolerance, automate onboarding, and scale safely.

They also discuss why early-stage fintechs often fail to prioritize compliance—and how Travis's team offers a free tool to change that. This episode is a must-listen for anyone looking to grow responsibly in today's complex financial environment.

GUEST-AT-A-GLANCE
Travis Dulaney
CEO and Co-founder
BalancedTrust
LinkedIn
Noteworthy: 25+ years in fintech, building scalable, compliant solutions for banks and startups

KEY INSIGHTS

Lack of Standardization Is Slowing Fintech Growth

Compliance challenges aren't just technical—they're human. One of the biggest bottlenecks for fintechs trying to scale is the lack of standardization in how sponsor banks evaluate risk and onboard new partners. As Travis explains, different banks—and even individual BSA officers—interpret and apply compliance rules inconsistently. This leads to wildly different outcomes for the same applicant, creating confusion and wasted effort. The core issue isn't always regulation but the subjective way it's enforced. Fintechs often get rejected not because they're too risky but because they don't speak the bank's language or follow an expected format. This inconsistency drags innovation, limits access, and leaves founders guessing how to move forward. A more structured, transparent process would benefit banks and startups by aligning expectations and removing friction.

Compliance Isn't Optional—It's a Growth Enabler

In the startup world, speed often wins. However, regarding financial services, speed without compliance leads to dead ends. Travis argues that compliance isn't a box to check—infrastructure helps fintechs grow. Too many early-stage companies treat risk management like a burden rather than a foundation. That mindset leads to breakdowns when securing a sponsor bank or raising capital. BalancedTrust was built to address this gap by giving fintechs a more precise roadmap: show where the risk lies, understand the rules that apply and know what actions to take. Travis points out that banks won't tell you how to fix your gaps—they're not liable for your mistakes. That's why having a structured, proactive compliance plan helps startups build trust, gain partnerships, and move faster with fewer surprises.

Stablecoins - The Missing Link in Cross-Border Payments?
While stablecoins are often discussed through the lens of crypto speculation, Travis highlights a more practical role: solving the long-standing pain point of the international money movement. Stablecoins, backed by fiat and supported by wallets on both ends, offer a fast, transparent, and secure alternative. They can bridge traditional banking and decentralized finance, creating a unified standard for moving value across jurisdictions. But Travis emphasizes that the real value isn't just technical—it's compliance-driven. If regulators and banks can confidently trace the source and destination of funds, then stablecoins will become more than a crypto tool—they will become infrastructu

Send us a text

EPISODE SUMMARY
This episode of Wrestling Payments tackles the critical topic of exposure limits in modern payments. Host Joe Casali and guest Sean Carter, President & CEO of Neach Payments Group, dissect an article by Jordan Bennett of Nacha, which focuses on payment modernization and digital transformation. Sean highlights a common misconception: viewing exposure limits solely through the lens of credit risk. He argues for a broader perspective, emphasizing operational risks like account takeovers and business email compromise.

Sean explains how current exposure limit practices often focus on the unlikely event of a business's complete failure, rather than the more frequent occurrences of chargebacks and return items. He advocates for a more holistic review process, considering IT security practices and overall risk management. Sean also discusses the challenges financial institutions face with third-party senders and the importance of consistent due diligence.

Finally, Sean challenges the common practice of assigning uniform exposure limits. He urges listeners to consider the unique risks of each originator and leverage available tools for efficient limit monitoring and enforcement. This episode provides valuable insights for financial institutions looking to strengthen their payment processes and mitigate risk.

Sean Carter
President & CEO
Neach Payments Group and NEACH
Payments risk expert advocating for holistic exposure limit reviews.
LinkedIn

KEY INSIGHTS
Rethinking Exposure Limits

Exposure limits are often mistakenly viewed solely through the lens of credit risk. This narrow focus overlooks the significant operational risks prevalent in today's digital payment landscape, such as account takeovers and business email compromise. A more comprehensive approach considers a company's IT security practices, overall risk management, and the potential for fraud, ensuring a more robust and effective risk mitigation strategy. Shifting the focus from the unlikely scenario of complete business failure to the more frequent occurrences of chargebacks and returns offers a more practical and relevant assessment of risk.

Third-Party Sender Oversight

Financial institutions must extend their rigorous risk management practices to third-party senders. While institutions may have robust internal controls, neglecting the oversight of third-party partners creates a vulnerability. Ensuring these partners adhere to the same level of due diligence and risk assessment is crucial for maintaining a strong security posture and protecting the institution from potential fraud and operational failures. This includes implementing agreements and monitoring processes to guarantee consistent security practices across the payment ecosystem.

Send us a text

EPISODE SUMMARY
It happens to the best of us. This session was recorded last year, but got lost in the shuffle. It may be a crime as the interview was with law enforcement and a member financial institution (at the time) on the topic of fraud... the show notes below.

In this episode of Wrestling Payments, host Joe Casali engages in an insightful discussion with Matthew Hogan, CAMS, a detective with the Connecticut State Police and a Task Force Officer with the USSS Financial Crimes Task Force, and Ryan McKinnon, Senior Deposit Operations Fraud Analyst at South Shore Bank. The conversation dives into the complexities of fraud detection and prevention in the financial sector, highlighting the collaborative efforts required between financial institutions and law enforcement.

Matthew Hogan shares his experiences investigating white-collar and cryptocurrency crimes, emphasizing the critical need for timely reporting and effective communication between banks and law enforcement to combat fraud. He underscores the challenges of prosecuting financial crimes, particularly those involving international actors and the increasing use of cryptocurrencies for money laundering.

Ryan McKinnon discusses his role at South Shore Bank and the importance of education and community outreach in fraud prevention. He highlights the need for financial institutions to stay vigilant and adaptive to evolving fraud tactics.

GUEST INFORMATION

Matthew Hogan
Detective
Connecticut State Police
(23) Matthew Hogan, MS | LinkedIn

Ryan McKinnon
Assistant Manager Fraud & Recovery
Charlesbridge
(23) Ryan McKinnon, CAMS | LinkedIn
(formerly Sr Deposit Operations Fraud Analyst with South Shore Bank)

KEY INSIGHTS
Financial Institutions and Law Enforcement Must Collaborate

Effective collaboration between financial institutions and law enforcement is crucial in combating financial fraud. Banks often detect scams but need proper communication to address the full impact. Law enforcement relies on detailed reports from banks to investigate and prosecute fraud cases. However, there's often a communication gap, with banks unaware of the outcomes and law enforcement not providing feedback. Bridging this gap can enhance fraud detection and prosecution, ensuring both sides work together more efficiently. Regular interactions and feedback loops between these entities can significantly improve the response to financial fraud.

Cryptocurrency is a Major Vehicle for Modern Financial Fraud
Cryptocurrency is a significant tool for laundering money and committing fraud due to its anonymity and ease of transfer. Financial institutions and law enforcement face scams involving cryptocurrency, from thefts to Ponzi schemes. Understanding cryptocurrency transactions and fraud tactics is crucial for developing countermeasures. As fraudsters innovate, staying informed and vigilant is vital. Preventative measures and investigative techniques must evolve to keep pace with the changing landscape of financial fraud involving digital currencies.

Fraud Tactics Evolve but Core Elements Remain Constant

Fraud methods evolve, but the core elements remain the same: urgency, a problem or prize, and a specific payment method. This consistency helps financial institutions develop effective detection and prevention strategies.

Send us a text

EPISODE SUMMARY

Sarah Stapp, Chief Commercial Officer at Aeropay, joins Joseph Casali to discuss the evolving payments landscape, focusing on Pay by Bank. Sarah shares her unique journey into fintech, from Craigslist job ads to leading global expansion at Braintree, and dives into ACH rails and real-time payments.

Why Pay by Bank Matters: It offers fast, secure payment options directly from bank accounts, bypassing card networks. Sarah highlights how RTP and FedNow are shaping user expectations around speed and control across industries like gaming and insurance.

Key Topics:

• Evolution of payment orchestration
• Understanding “guaranteed ACH”
• Signals of Pay by Bank's growth in the U.S.
• Consumer-driven adoption over regulation

GUEST-AT-A-GLANCE

Sarah Stapp Chief Commercial Officer, Aeropay LinkedIn

Noteworthy: Spent 12 years at Braintree, leading global expansion.


KEY INSIGHTS

Pay by Bank Is Here: Sarah explains how direct bank-to-bank payments using ACH rails and mobile authentication are gaining traction, especially in gaming. She emphasizes the importance of education for both merchants and consumers.

Instant Payouts: RTP and FedNow are changing consumer expectations for receiving money. Sarah discusses the impact on gaming, insurance claims, contractor payments, and rent reimbursements.

Guaranteed ACH: Sarah introduces “guaranteed ACH” to mitigate risks associated with traditional ACH, offering merchants fewer chargebacks and better cash flow.

Payment Orchestration: Sarah unpacks payment orchestration, highlighting its role in optimizing transactions, centralizing customer data, reducing costs, and enhancing user experience.

Send us a text

Episode Summary

In this episode of Wrestling Payments, host Joseph Casali breaks down three timely developments in the payments world. First, he tackles the slow adoption of faster payments among smaller financial institutions. Despite strong growth in RTP and FedNow, integration costs and a lack of clear pricing models continue to hold many back.

Next, Joe explores Square’s move to offer consumer loans through Cash App. With FDIC approval in hand, Square—under its parent company Block—is entering the credit space with small, short-term loans. Joe weighs the pros and cons of fintechs stepping into traditional banking roles, especially as regulators start paying closer attention.

Finally, the discussion shifts to stablecoins. The OCC has relaxed its stance, making it easier for banks to engage in crypto-related activities. Joe walks through proposed legislation and asks the big question: who should regulate stablecoins, and what does that mean for banks and consumers?

KEY INSIGHTS

Small Banks Lag in Real-Time Payment Adoption

Despite the growing infrastructure behind faster payments like RTP and FedNow, smaller financial institutions continue to trail their larger peers. Joe points out that big banks are six times more likely to offer real-time payments. The reasons? Integration complexity, unclear pricing strategies, and rising deposit costs. About 30% of hesitant institutions lack a pricing model, and 35% cite tech integration as a barrier. While over 70% of regional and national banks allow consumers to send real-time payments, only 44% of credit unions do the same. The opportunity is there—but hesitation remains.

Square’s Cash App Loans Signal Fintech’s Banking Ambitions

Square, now operating under parent company Block, has secured FDIC approval to offer small-dollar loans through Cash App. Joe unpacks how these short-term, low-cost loans are aimed at underbanked consumers facing steep fees from payday lenders or overdrafts. The average loan is under $100, repaid within a month, and has a default rate below 3%. With nearly $9 billion originated already, this product has clear demand. Joe raises important questions around regulation, noting that while fintechs offer convenience, they aren’t held to the same standards as banks—yet.

OCC Opens the Door to Crypto Activity in Banking

The Office of the Comptroller of the Currency (OCC) has issued new guidance making it easier for banks to engage in crypto-related services like stablecoin issuance and blockchain verification. This removes the previous requirement for individual “non-objection” letters, streamlining the process. Joe explains how this policy shift reflects growing acceptance of crypto in financial systems and reduces compliance hurdles for banks. But he also warns: without consistent regulation across fintechs and banks, consumer trust and financial stability could be tested.

Stablecoin Legislation Could Reshape the Payments Landscape

Congress is actively working on several stablecoin bills, including the Stable Act and Genius Act. Joe reviews draft proposals that would require stablecoin issuers to hold liquid reserves—like short-term Treasuries—and submit to state or Federal Reserve oversight. One provision caps stablecoin issuance at $10 billion per entity, which Joe questions as being too low to make real market impact. With PayPal and other major players eyeing this space, the legislation could set the tone for how digital currencies coexist with traditional money movement.