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Brandon Hall Award - Best Advance in Compliance Training
Interactive Advantage Wins 2020 Brandon Hall Group HCM Silver Excellence Award!
Category: Best Advance in Compliance Training
Entry Title: How Interactive Advantage used Lectora to Automate and Personalize WesPay's ACH Compliance Training
The entries were evaluated by an international panel of independent industry experts, Brandon Hall Group senior analysts and executive leadership team. The judging was based on the following criteria: fit the need, design of the program, functionality, innovation, and overall measurable benefits.
Business Conditions and Business Needs
Each time someone enters a bank account and routing number to make a payment such as direct deposits, an ACH (Automated Clearing House) transaction occurs. The transaction starts with a commercial ACH Originator, usually a business or payment provider. The Originator creates a specially formatted file and submits it to their partner Originating Depository Financial Institution (ODFI). The ODFI transmits entries into the ACH Network on behalf of the Originator. Eventually, the transaction is completed, and funds are deposited into the desired account.
The entities involved in this complex process each take on responsibilities to obtain proper authorization, maintain security, and minimize returns. Regulators are increasingly looking for proof that financial institutions are providing the proper tools and guidance to customers and members participating in U.S. payments systems. To mitigate the risks and achieve compliance, ODFIs are encouraged to work with Originators to ensure they have proper controls and oversight over their payment processes. National Automated Clearing House Association (NACHA – now Nacha) manages the ACH Network and provides the Nacha Operating Rules, a set of rules that guide risk management. While ODFIs often provide guidance and training for their partner Originators, very few tools if any are available in the marketplace to deliver effective web-based instruction on the Nacha Operating Rules, provide online self-assessments for compliance, and track compliance assessment results in an automated way. This means ODFIs may not be aware of which Originators understand the complex and changing rules and to what degree the Originators are prepared to achieve and maintain compliance. Originators may have difficulty knowing which rules apply to them and whether steps need to be taken annually to address compliance issues. Due to a lack of verifiable comprehension, risk is introduced and both entities may struggle to pass audits related to ACH transactions.
The WesPay Learning Center was created to address ACH Originator compliance training, assessment, and verification needs. The following goals for the were established and achieved:
Create an online learning center structured to provide ODFIs with an affordable turnkey solution for ACH Originator training, assessment, and verification – ODFIs subscribe to the WesPay Learning Center as instructional administrators and enroll partner ACH Originators in training and assessment activities. This can be done in a matter of days, making this solution ideal for ODFIs striving to show proof they are providing the proper tools and guidance to Originators.
Create a flexible system capable of easily supporting annual content updates and custom functionality – The Lectora Publisher development tool from Trivantis supports a wide variety of asynchronous content resources and interactive assessments, all of which can be easily updated as rules change. Training videos are added as they become available. Documents are stored on the system server for easy maintenance and easy access by users. The primary resources on the WesPay Learning Center, the self-assessments, are outfitted with new custom functionality each year as new Nacha rules and guidelines require conditional branching. ODFIs can also request co-branding whereby as single assessment will show specific branding elements based on the user’s profile. This helps reinforce the relationship between the ODFIs and their partner Originators.
Deliver a personalized experience with timely resources and self-assessment tools that are applicable to each Originator’s unique ACH activities – The resources provided on the Learning Center are designed for users who may not have the time or propensity to keep abreast of evolving Nacha Operating Rules. For example, the self-assessments help the user rapidly build a profile identifying their institutions specific demographic in the complex ACH transactions industry. Profile information is used by system code to dynamically serve up the applicable category of rules and associated questions for the Originator. This eliminates guesswork and enables users to easily become aware of and focus on applicable compliance topics. When a user completes a self-assessment, a personalized compliance strategy is generated in PDF format for the Originator as a tailored plan of action to address compliance issues.
Provide detailed reports to ODFI subscribers for tracking, training interventions, and verification – ODFIs must be able to prove to regulators and auditors that appropriate steps are being taken to make sure Originators follow Nacha rules. These steps must be effective, and they must be documented. To address this need, ODFI subscribers have access to system reports fed by Lectora data showing which partner Originators have accessed and completed training and self-assessments. In addition, automatic alerts are sent by the system to the assigned ODFI contacts when personalized compliance strategy PDFs are generated for each Originator under their purview. A copy of the PDF is sent to the ODFI contact. ODFI subscribers thus gain unique insight into Originator weaknesses, prescribe personalized training, document Originator participation, and identify trends across groups of Originators. The reports available to the ODFI comprise the information required by regulators and auditors, making the audit process easier and more successful.
Design and Deployment of the Program
The WesPay Learning Center was designed with a focus on the following components to ensure a smooth annual deployment and an optimized user experience:
Instructional Design: The content and questions presented in the training and assessment material is designed with the audience in mind. Although most in the target audience come to the Learning Center with some ACH transactions experience, specific knowledge of rules is often out of date and incomplete. Misunderstandings of the complex regulations are common. For this reason, the content is written in plain language and in layman’s terms. Rather than presenting all the learning material and following with an assessment, learning concepts are presented in the context of questions designed to identify compliance issues. The self-assessments also include a demographic form that must be completed prior to answering questions. The demographic questions help to identify the institution’s size, types of transactions they process, and other factors that determine which categories of Nacha rules apply. Thus, only the content and questions appropriate for the user are presented.
User Experience: Since most of the users in the target audience are financial experts, not technical experts, a focus was placed on ease of use. This started with the user interface design. The Learning Center home screen is simple and clear. Users see options to view FAQs, their profile, and a list of activities in their Learning Plan. To avoid popup blockers and active content blockers, a potential source of frustration for non-technical users, the Moodle SCORM player was customized to present the self-assessments within a frame in the main window rather than a separate window. Perhaps the most important aspect of the user experience was a common concern about downloading and installing plug-ins or special software, something typically limited at financial institutions due to security concerns. The entire Learning Center and all of its assets run in all standard browsers and devices without the need for plug-ins or any special software or hardware. This means users can simply click the link they receive via email and begin learning. Very little technical support is required.
Security: ODFIs, like other financial institutions, are sensitive to potential privacy and security issues. For this reason, users are registered and enrolled in the system by ODFIs via a user upload spreadsheet. Instructions are provided to each new ODFI subscriber to make the process quick and easy. Users are grouped according to their ODFI organization so that private information cannot be viewed by unauthorized parties. Anti-virus and other security measures are employed and kept current in the server environment. The Moodle system is regularly updated, and security patches applied. SSL certificates are in place for the Development and Production environments to ensure credential security.
Change Management Efforts
WesPay is a not-for-profit association with a limited budget for the Learning Center. It was recognized early on that the non-technical users might require a substantial technical support budget if measures weren’t taken. WesPay and the solution provider, Interactive Advantage, collaborated to define preventative measures and workflow processes designed to reduce the technical support burden. Statements of work were created to capture the level of effort, define the expected outcomes, and identify the costs associated with the work. Early efforts to train ODFIs on how to properly register and enroll users, coupled with customization of the Moodle SCORM player to eliminate popup blocker issues and intuitive interface designs, have kept technical support costs low and stable (no change in labor hours for the past four years) despite significant annual increases in the number of users and learning assets available in the system.
Data on how many and to what degree the participating ACH Originators achieve compliance with Nacha Operating Rules is private and cannot be directly measured. However, it is fair to say this is the only known solution of its type in the ACH transactions industry and it is having a positive impact. To date, about 7,000 ACH Originators have accessed learning resources on Nacha Operating Rules, self-assessed their compliance based upon their unique processing environment, and created personalized strategies to address compliance issues. For the ODFI subscribers, WesPay Learning Center provides a tangible demonstration to auditors and regulators that proactive steps are being taken to train partner Originators and help them comply with the Nacha Operating Rules. More ODFIs are recognizing this as an affordable turnkey solution to meet their obligations. For this reason, the annual subscription base has grown from a few ODFI groups in 2014 to over 150 ODFI groups and growing. WesPay’s annual solution budget is covered by subscription revenue. More importantly for WesPay, ODFIs, ACH Originators, and others involved with ACH transactions, the increased levels of awareness and compliance ultimately drive a more secure and successful ACH Network.
The WesPay Learning Center has proven to be a successful endeavor for WesPay, the ODFI subscribers, and the ACH Originators. In addition to meeting its stated objective of lowering risks associated with ACH origination, the solution is strengthening relationships between ODIFs and their partner ACH Originators. This success is encouraging WesPay to grow the Learning Center. It was recently expanded to include a Remote Deposit Capture (RDC) self-assessment and associated training material that addresses Nacha rules for check processing. Self-assessments for other payment channels such as Third-Party Sender are a possibility in the future.