Vous êtes sur la page 1sur 10

2

© Payment Pathways, Inc. 2009


3

Description of Greenlist® — A Method for


Expediting Electronic Payments (July 2009)
Richard J. O’Brien, Jeff Morrow, Ralf Seiffe and David Farber

A Greenlist® ID, or GLID, is SAFE because


Abstract— Greenlist® is a new, patent pending business
method available only to banks to improve the authorization and
debits will never be processed against a Greenlist®
execution of time-sensitive asset transfers, primarily payments ID without the owner’s prior approval. Only credits
but also transfers of confidential information assets such as and messages will be processed against a Greenlist®
medical records or other sensitive securitized assets. The
Greenlist® is a directory service that verifies identities and
ID without approval. Furthermore, all messages will
payment addresses before financial transactions are made or come from a bank and will not be spam or
before obtaining access to restricted information. In practice, marketing messages.
Banks query the Greenlist® to provide payors a means to locate,
validate and effect the instant transfer of assets. This reduces
A GLID is SAFE because anyone sending money
transfer time and is accomplished without divulging the payee’s to a Greenlist® ID is given some information
confidential information. identifying the payee and providing a dispute
Banks. the lowest cost risk bearers, maintain the Greenlist® history about that payee.
by becoming trusted registrars who assume the risk for identity-
related fraud based on the information contained within the A GLID is SAFE because information linking a
registry. This liability transfer substantially reduces the payor- payee’s bank account to a GLID is never disclosed
bank’s cost of bearing risks because they are left with only those to a payor.
risks associated with payor authentication and authorization.
These risks are entirely in their own control. A GLID is SAFE because it is coupled with a
Banks or third parties responsible for certifying that someone matching Virtual Identifier (VID) to minimize
or some entity claiming to be an authorized party is not an keying errors. (The VID can also act like a CVV.)
impostor can now offer new levels of service at a substantially
lower cost for a variety of transactions. This enables assets to be The Greenlist® services are bank-centric. To get
transferred irrevocably so ‘good funds’ can be credited instantly the full range of Greenlist® services, a Greenlist®
upon receipt and essential parties can be immediately notified cardholder must be sponsored and registered by a
that the asset transfer has been settled and with utmost
transparency. bank that has agreed to abide by the Greenlist®
rules. A more limited set of services is available to
Index Terms — Multistage interconnection networks, risk self-registered individuals; entities that are not
abatement, transfer standards, ultra-large-scale integration, natural persons cannot self-register.
expedited payments.

Greenlist® is a registered trademark of Payment Pathways, Inc.

I. INTRODUCTION
What is Greenlist®? It is both a directory of safe
payment addresses and a set of payment and billing
services that use that directory. The Greenlist® services are accessible through
either through a web-enabled mobile phone1 or
through the combination of a PC and phone, either
Richard J. O’Brien is with Payment Pathways, Inc., Chicago, IL USA landline or mobile.
312-346-9400. robrien@paymentpathways.com. The Greenlist® services involve little
Jeff Morrow is EVP at Dollar Bank in Pittsburgh, PA.
jmorrow842@dollarbank.com. enhancement to existing bank payment
David Farber is professor of Computer Science and Public Policy in the infrastructures.
School of Computer Science at Carnegie Mellon University and in the Heinz
School of Public Policy, Pittsburgh, PA USA. Dave@farber.net
Ralf Seiffe is principal at Transmedial Communications, LLC, Skokie, IL,
1
USA. rseiffe@truthinaccounting.org A text-message-enabled phone will provide limited access to Greenlist
services.

© Payment Pathways, Inc. 2009


4

The basic services supported are: information confirming the identity of the payee
• Guaranteed small value payments, either (such as telephone number or, in the case of a
instant or next banking day, with immediate business, a name), and a dispute history. Depending
electronic notification to the payee. on whether the payor has sufficient funds and the
• Electronic bill presentment. payor’s bank is content with the dispute history, the
• “Instant” bill payment. payor’s bank decides whether to pay or not pay.
• An “unhackable” number for small-value If the decision is to pay, the payor’s bank
purchases online. provides to the payor the information identifying
To keep things simple, we shall assume in the payee and the payee’s dispute history and asks
discussing the services that customers are bank- for confirmation to proceed with the payment. This
registered customers. confirmation can occur either during the online
A. X2X Guaranteed Small-Value Payments session or through a separate channel initiated by
the payor’s bank.
This is a generalized GUARANTEED payment Once confirmation is received and the
service, a kind of electronic certified check with payor’s account has been debited, what the payor’s
instant electronic notification. It is for payments bank does next depends on whether payment is for
involving small amounts because it imposes risk on next banking day or for instant credit. If next day,
participating banks that is unacceptable for large the payor’s bank originates an ACH credit for
amounts. The sender can be a person or a small settlement on the next banking day addressed to the
business or organization. The receiver can be a payee’s bank and sends an immediate electronic
person or a business or organization of any size. It notification of guaranteed payment to the payee’s
is more than P2P. It covers P2P, P2B, B2P, and bank. If instant, the payor’s bank sends a credit
B2B for small payments. addressed to the payee’s bank through Pulse.
The payee’s bank in turn notifies the payee
electronically that payment has been guaranteed and
is either available immediately or on a particular
day, depending on what the payor specified.
B. Bill Presentment
Because a bank participating in Greenlist® can
determine through the Greenlist® directory what is
the bank of a Greenlist® cardholder, a participating
bank can send information, such as a bill, “care of”
the cardholder’s bank. The cardholder’s bank is
obligated to forward that information to the
How does it work?
cardholder.
Using an access device and whatever security
So the Greenlist® services automatically permit
process the bank has selected, the payor signs in to
electronic bill presentment from any Greenlist-
the payor’s online banking site. Once signed in, the
registered biller to any Greenlist cardholder.
payor uses the payee’s GLID and VID to authorize
payment to the payee. The payor can specify that C. “Instant” Bill Payment
payment is to be immediate or next (banking) day. It is obvious that the X2X guaranteed payment
The payor’s bank confirms with the Greenlist® service completely addresses “instant” bill payment.
Directory that the GLID and VID match and obtains
D. Un-hackable Internet Purchases
from the Greenlist® Directory routing information
to make payment within the indicated time,2 public A Greenlist® customer receives a card
WITHOUT A MAGNETIC STRIPE that shows the
2
This routing information will include a RT number or a BIN. It will not
include a true account number. It will instead include a pseudo-account receiving the money. A sending bank will not get information about the
number that must be translated into a true account number at the bank account numbers of customers of other banks.

© Payment Pathways, Inc. 2009


5

customer’s VID and a special Internet purchasing Self-registered customers will be provided a login
number, which conforms to the rules for a signature id and a password for a special site hosted by the
debit card number. All requests for authorization Greenlist® bank.
that purport to be card-present transactions will be A self-registered customer who wants to make a
denied. If the number is used in a card-not-present payment goes to the special site and purchases an
situation, the bank will not authorize for shipment electronic money order payable to any GLID. The
to an address other than the address on file at Greenlist® bank then transmits the money exactly as
Greenlist® or for amounts greater than a low dollar it would for a regular Greenlist® payment and
amount.3 No authorization will be granted if the collects using an ACH debit. If the ACH debit is
customer’s phone number or email address differs returned, the Greenlist® bank asks for an
from those on file at Greenlist®. Whether or not the authorization against the credit card, funds that way,
bank authorizes the transaction, the bank will notify and charges the self-registered customer a penalty.
the Greenlist® customer of the amount and A self-registered customer can receive electronic
merchant who requested payment. The Greenlist® bills just as any other Greenlist customer can.
customer will have a certain period of time in which A self-registered customer can receive payments,
to authorize the payment. but not on an instant basis.
If the payment is not authorized by the Greenlist® A self-registered customer can make un-hackable
customer within that time, the bank will first notify internet purchases. To make them, the customer
the merchant that the authorization is invalid and if must first come to the site for unregistered
the merchant insists on settlement, return it as an customers and activate the internet purchase number
unauthorized card-not-present transaction. No for a period not to exceed two hours by pre-
money will be deducted from the Greenlist® approving transactions for amounts (not to exceed a
customer’s account unless authorization is received customer designated limit) from certain types of
from the customer even if the bank ends up having merchants.
to pay a merchant.
E. Self-registration II. GLOBAL VISION
The key question is whether it is possible to What is the best predictor of a successful
provide these services if only one bank is involved. financial transaction?
The answer is “yes.” Since the first traders began exchanging their
Any customer with a valid credit card can self- possessions, the best predictor has been knowledge
register. Self-registration permits use of all of the identity of the other party. The size of a
Greenlist® services except receiving instant transaction, the distance between traders, the nature
payments. Self-registration will involve some sort of the transaction, or even the languages of the
of identifying system such as Verid. There will be a parties do not change the need to know the identity
small one-time fee to join. The fee will be over- of the other party to a transaction.
charged to the credit card as a card-not-present But the question, “who am I doing business
transaction, and a credit will be made to the same with?” does not always have an obvious answer. In
account for the amount of the over-charge. Before
today’s fast paced, computer dependent world,
registration is complete, the self-registrant must
people make purchases, payments, deposits, and
specify the amount of the credit received. This
other financial transactions without the exchange of
shows that the customer has access to the account
information for the card number provided. During money, checks, or even the simple act of handing a
self-registration, the registrant also provides the RT teller a credit or debit card. Many transactions made
number and bank account number of the registrant by individuals today are done over the telephone
as well as phone and email information for and Internet. Such a public forum requires security
notifications. measures, which are often tedious, inconvenient,
and can cause long delays in what are otherwise
3
If the customer wants to make a purchase that does not conform to these simple transactions.
limitations, the purchase must be pre-approved through a bank’s online site.

© Payment Pathways, Inc. 2009


6

For both buyers and sellers, authentication of the networking to expedite electronic payments
participating parties has become a high-value between individuals, between individuals and major
assurance of security, the absence of which leads to billers or between an individual and a merchant in
transactions risks and inefficiencies. Because either an online or retail setting.
payees are reluctant to divulge their private account
numbers without the assurance of the safety, many III. REGISTRARS
transactions continue to be made by cash or check The following accreditation steps are necessary to
because payors cannot obtain the recipient’s create Registrars with necessary permissions in the
electronic payment address. For example, when Administration and Security Application to create
funds simply have to be transferred instantly to and maintain the Greenlist® registry. When such
another party, inefficient means are used such as steps are completed, registrars can certifiably enroll,
overnight delivery services, travel to a money- add, delete and edit registrants’ data in the registry.
transfer business, payment of check-cashing fees A. Registrar accreditation
upon receipt, etc.
Organizations must be accredited to become a
Security is a major concern for online consumers,
registrar. The registry manages the accreditation
too. Consumers shun utilizing pervasive networks
process based on a series of accreditation
such as the Internet and mobile networks because
requirements agreed with the Greenlist® Rules
they worry that they might need to repudiate a
Council. The council’s authority is created by
payment if goods or services are not received.
consensus of participating Greenlist® Pilot Banks.
The Greenlist® business method can accelerate
It is comprised of representatives from banks and
the migration to pervasive electronic payment
participating payment network stakeholders.
systems by transferring the risks of providing
To become a registrar, a bank must be in
electronic payment addresses from payors to more
compliance with its regulator’s requirements for
suitable registration entities. Banks can—and
capitalization and remain in good standing in order
should—validate the identity of counterparties and
to continue functioning as a registrar. Registrar-
mitigate concerns related to electronic transactions.
banks accept liability for any consequential
Using a priori information banks can supply data
damages should its registrants’ data be proven
pertaining to the counterparties’ histories of
inaccurate. To expedite asset transfers, banks must
completing transactions successfully.
be certified as an Account-to-Account sender by at
least one debit network and agree to never debit any
ACH payment addresses retrieved from queries to
the Greenlist®.
Every registrant is issued a debit-blocked
Personal Account Number (PAN) that conforms to
INCITS/ISO/IEC 7812-1-2000 and 7812-2-2000.
Registrar-banks or their proxies must not put the
registry in breach of the laws on the protection of
personal information, or allow the registry to be put
in this position because of the registrar’s inaction.
B. Registrar responsibilities
But before banks can become arbiters of identity
and purveyors of transaction histories, they must Registrars’ agree it is important that a registrant
first build peer-respected capacity. The Greenlist® is fully informed and that they understand the
Transfer Protocol (GTP) is a rule-set for banks to service levels and all relevant charges they should
construct, implement and maintain identity and expect. Registrars ensure that registrants are aware
transactional information services via pervasive of the charges associated with registration and

© Payment Pathways, Inc. 2009


7

renewal. This includes giving details of the related paid by putting control of payment release into the
services provided which are relevant to the hands of the consumer or small business. Certain
customer. large billers may discover ways to incentivize their
The registrant needs to understand the terms of customers to expedite payments on actual due dates
their contract. Therefore, the registrar must make in order to lower interchange fees. Another is when
registrants aware of the current version of their a small or even medium sized business is a health
Terms and Conditions before the Contract is made care provider and the party billed is an insurance
and state how registrants will be made aware of carrier. Up to now, these entities have been
changes to the terms. reluctant to provide their bank account information
C. Registrar’s relationship with the registry to the carriers. Providers fear that payments, for
charges (that are later determined to NOT be
Greenlist® users must understand the relationship
covered by an insurance policy) could be debited or
between their registrar and the registry and
“clawed back” immediately, instead of being
registrars should take the steps to properly inform
reconciled in the next month’s payment cycle.
their customers and the public. To ensure all
Banks, functioning as Greenlist® registrars, enroll
registrars have a good understanding of the
small businesses (such as health care providers) in
technology and business processes involved in
the Greenlist® and assess service fees. A portion of
registrations, a new registrar will be asked to
this monthly fee is net income, and a portion of the
complete a course to demonstrate a basic
fee is used as net income for registrars to list debit
understanding of the Greenlist® registration and
blocked (or debit filtered) payment addresses in the
maintenance process.
public Greenlist®. In Healthcare, a Clearinghouse
D. Proxy Registrars through its Greenlist® registrar-bank, can serve the
Proxy registrar is the term used to broadly Insurance Carriers by instituting a company to
define any non-bank institution that is duly function as a proxy registrar (for banks) and
authorized by an accredited registrar-bank to enroll perform Greenlist® enrollment functions by
a large number of users at one time. Examples obtaining a system use license.
range from healthcare clearinghouses to mobile F. Liability and Risk of Proxy-registrars
network operators. Such institutions are now
A registrar should be aware that if they operate a
addressing the emerging needs for Electronic
proxy-registrar program, that registrar assumes
Remittance Advisory (ERA) payments. ERAs are
liability for the actions of its proxies.
mandated for Medicaid and Medicare, and many
The Contract makes the actions of proxies the
insurance carriers are implementing ERAs for all
registrar’s responsibility so it becomes the
payments. These payment communities all require
registrar’s responsibility to stop the proxy from
the ability to settle payments without today’s
doing anything that would breach the registrar
security risks and payment delays.
agreement or accreditation requirements or to stop
E. Benefits of Proxy Registrars them being one of its proxies.
The use of a Greenlist® eliminates the potential In the event that a problem arises, registrars must
risk of overdraft associated with Debit-ACH be properly reserved or insured. At minimum, the
transfers by issuing Credit transfers via one of registrar must provide evidence that the applicant
several payment networks, depending on the has appropriate professional indemnity insurance in
payment application’s requirement. In addition to place. This should be cover of at least $500,000.
the efficiencies associated with authentication G. Notifications and Associated Responsibilities
services provided by parties in the position to do so
All registrars are required to publish a code of
with the least cost (e.g., banks), in the healthcare
practice for complaint handling and dispute
context that use is augmented by subtler uses. One
resolution, including escalation plan and record
is a reversal of the way that recurring billers are

© Payment Pathways, Inc. 2009


8

such events to the registry log. successful, the customer information will be
The registrar must provide details of any relevant updated on the master GL Database. An update
litigation or regulatory enforcements e.g. details of confirmation will be returned via the GL Server. If
any regulatory fines, any outstanding court the enrollment is not successful for any reason, the
judgments or details of any ongoing legal actions. API will return an error code and description.
H. Batch Enrollments and the “Hold” Status C. Customer Look-up
Minimally, to receive temporary “Hold” on This use case allows an authorized application to
various identifiers such as GLIDs, Greenlist® look up a GL Customer in order to submit a
accepts batch registrations. payment or a payment request. This lookup occurs
I. When to transition off “Hold” status when the Payee does not belong to the same bank as
the Payor.
Proxy registrars submit batch enrollments.
Some examples are: Billing & Payment Service The Payor will enter a GLID to search for a GL
Providers, Mobile Carriers, or a Healthcare Customer. The Lookup API will return available
Clearinghouses. En masse registrations by proxies name and address data along with LCA-PAN of the
are automatically put on “HOLD” status for thirty matching GL Customer.
days. This provides the customer sufficient time to
experience some limited application functionality
and learn more about the benefits of a fully certified
registration. When he authorizes a registrar-bank to
complete his registration, his enrollment is complete
and status becomes “Active” so instant payments
can arrive.

IV. PROCESS DESCRIPTION


A. Enrollment
This use case allows a bank customer to enroll in
Greenlist®. The customer submits the necessary
enrollment information via the bank application.
During enrollment the registrant can select a
Greenlist® ID (GLID) as his or her public payment
identifier. The registrar-bank’s online portal Alternatively, Home Phone Number, Cell
application will then submit the enrollment request Number or E-mail address can be used to search for
to the GL Server. If the enrollment is successful, the GL Customer. The API will return a reduced set of
customer information will be stored in the database information for non-banks, which can be used to
and a Virtual Identifier (VID) will be created for submit an invoice to the GL Customer. If the GL
that registrant. If the update is not successful for any Customer Lookup is not successful for any reason,
reason, the API will return an error code and the API will return an error code and description.
description.
D. Manage Customer Transaction Information
B. Manage Customer Information This use case allows the Greenlist® to record a
This use case allows a bank application to update transaction involving the transfer of money from
GL Customer Data in real-time or via a batch Payor to Payee account. The bank application of
processing method. The bank customer submits the both the Payor and Payee will submit the
necessary information updates via the bank transaction to the GL Server, which will in turn
application. The bank application will submit store the information about the transaction in the
updates to the GL Server. If the update is Greenlist® Master Database.

© Payment Pathways, Inc. 2009


9

E. Cancel Customer Registration V. FUTURE PROCESS FUNCTIONALITIES


This use case allows a bank customer to cancel A. Transaction History Information
their Greenlist® Registration. Once their registration This use case allows a bank customer to obtain
is cancelled, they will no longer be available for information about previous transactions involving
Greenlist® lookups. The bank customer submits the transfer of money to a Greenlisted payee that
their cancellation via the bank application. agrees to make its history of successful settlements
The bank application will then submit the as well as disputes available upon request.
cancellation request to the GL Server for validation.
If the validation is successful, the customer will be B. Information Transfer Restrictions
cancelled in the Greenlist®. A cancellation This use case allows a bank customer to grant
confirmation will be returned via the Bank’s GL- access to its personal information only to entities
enabled application to the customer. If the having certain credentials.
cancellation is not successful for any reason, the C. Information Transfer Notifications
API will return an error code and description.
This use case allows a bank customer to define
F. Manage Greenlist® Configuration various cases for him to be notified when an
This use case allows authorized PPI personnel to information transfer is sought. (notify and proceed,
modify certain configurable aspects of the notify to obtain separate permission, notify and
Greenlist® system. This includes the length deny access, etc.)
requirements that apply to Greenlist® ID (GLID)
selection, the holding period for a GLID after GL VI. NEUTRAL PERVASIVE NETWORK POSITIONING
customer enrollment changes, and reserved GLIDs. Without payment ubiquity, the network-effect
An administrative interface on the GL Server cannot snowball to achieve mass adoption. By
provides this functionality. The user navigates to steadfastly encouraging every network and core
the appropriate screen and the GL Server displays processor to support a common new component in
the current values for all configurable items. The the payment ecosystem, merchants and consumers
user updates one or more of the configurable items, alike will have multiple ways to learn about
submits the changes to the server, and the server Greenlist®. The first two Core Processors or Debit
validates whether the new values are acceptable. If networks to launch Greenlist® among its member
validation succeeds, the updated values are stored in banks may negotiate a limited time period of
the Master GL Database and the changes take effect exclusivity prior to other Debit network activations.
immediately for all subsequent API calls made to Account-to-Account credit transfer transaction
Greenlist®. If the update to any of the configuration services are in various stages of development at
parameters is not successful for any reason, the Pulse (Discover Financial Services), NYCE
system displays an error message. (Metavante, soon to be a division of Fidelity
G. Generate Pre-formatted Reports National Information Systems (FNIS), Exchange
EFT (Fiserv), and STAR (First Data Corporation).
This use case allows the Automated Report
PULSE and NYCE are exploring how to gateway
Scheduler to generate pre-canned reports. All
incoming credits to Greenlisted payment addresses
reports will be distributed via e-mail to a pre-
between their networks.
specified e-mail list.
All payment network stakeholders are affected
H. Generate Ad Hoc Reports positively, as the volume of credit payments &
This use case allows authorized PPI personnel to income increases without new capital expenditures.
generate and distribute ad hoc reports.
VII. ENABLING NETWORK INTEROPERABILITY
PULSE and NYCE are exploring how to perform
gateway services for incoming credits to

© Payment Pathways, Inc. 2009


10

Greenlisted addresses from each other’s network. the design and implementation process. Dialogues
with state and federal regulatory bodies continue.
VIII. INITIAL PILOT APPLICATIONS The Federal Reserve Bank of Atlanta has
Two Debit networks and one core processor, announced an ongoing study to learn how to
wishing to increase transaction volume and value, implement intra-day settlement with the ACH. The
will deploy Greenlist® in pilots beginning in Electronic Payment Network is working on an
August, 2009 among four licensed bank registrars. Account-to-Account transfer system that would
Each company strives to enable their bank and utilize identifiers that are eligible to be Greenlisted.
credit union customers to earn new revenue by We interpret these signs as proof that the banking
selling instant payment services to as many industry is prepared to rally around the leadership of
consumer and SMB accountholders as possible. the Greenlist® consortium banks. Another industry
A flat rate of one nickel ($0.05 fee) is charged for signal is the American Bankers Association
every query (a.k.a. lookup transaction) of one of convened an Interchange Task Force to tackle fraud.
several Greenlisted identifiers to discover a
Greenlisted payment address to be used by the X. CONCLUSION
payors’ bank to originate a payment. Banks recognize their fates are inextricably linked
Whenever an individual seeks to find or together. They agree that building a ‘commons’
authenticate any virtual addresses, they will trust infrastructure for use by all transacting parties is the
their bank’s Greenlist® to protect them. best way to grow Non-interest income (NII) while
achieving new economically meaningful levels of
IX. REGULATORY COMPLIANCE ISSUES service.
Greenlist’s open architecture enables search and
retrieval of trusted Identity information to achieve X. ACKNOWLEDGMENT
interoperability between any payment systems. This The authors acknowledge the support of Dollar
puts banks back into the center of the payment Bank, Pittsburgh, PA and Zenith Information
process, generating revenue from registrations and Systems, Inc. of Los Angeles, CA.
transactions. The thin nature of the directory and its
switch function adds a new factor of authentication AUTHORS
to safeguard bank payment transactions without Richard J. O’Brien B.A. McGill University (1976)
Mr. O’Brien is the co-inventor of the Greenlist® Transfer Protocol. He
adding the burden of regulatory compliance. currently is the President and CEO of Payment Pathways, Inc. in Chicago,
IL, USA, a company he founded in 2003 to commercialize the GTP.
Payment Pathways, during its sales process with
banks, accumulated insight into how banks have Jeff Morrow B.A. Columbia University (1966); M.B.A. Wharton School of
Finance (1972).
responded to the Federal Financial Institutions Mr. Morrow is the Executive Vice President of Dollar Bank F.S.B. of
Examination Council (FFIEC) guidance. Each bank Pittsburgh, PA. Mr. Morrow has direct responsibility for Branch
Administration and Services, Data Processing, Operations, and Community
that becomes licensed as a Greenlist® registrar Affairs and Development, in addition to Planning and Marketing.
informs its regulatory agency and explains how the David J. Farber B.S.E.E. Stevens Institute of Technology (1956) Doctor of
Greenlist® factor adds value and supports the intent Engineering, hon., Stevens Institute of Technology (1999)
Prof. Farber is Distinguished Career Professor of Computer Science and
of the FFIEC letter. By adding the Greenlist’s Public Policy in the School of Computer Science at Carnegie Mellon
identity verification factor for payees, any FFIEC University holding secondary appointments in the Heinz School of Public
Policy and the Engineering Public Policy Group. Dave sits on the FCC’s
compliant system becomes the safest system Technological Advisory Council and Advisory Council of the CISE
available today. Directorate of the National Science Foundation. He is a Fellow of the
Electronic Frontier Foundation and the IEEE.
The design for Greenlist® has been vetted with
the Federal Reserve Bank of Atlanta, the Office of Ralf Seiffe Bachelor of Business Administration, University of Wisconsin,
Madison, WI, USA ’76 Principal at Transmedial Communications, LLC and
the Comptroller of the Currency and the Office of co-founder of the Institute for Truth in Accounting, Northbrook, IL, USA.
Thrift Supervision. We received positive responses
and regulatory guidance that was incorporated in

© Payment Pathways, Inc. 2009

Vous aimerez peut-être aussi