Section title: Requests for Interpretation
RFI #
2374
Originating Company Identifier
Description

According to the 835 TR3, the Originating Company Identifier (DE 509) is reported in two places within the transaction, the BPR10 and TRN03. Both data elements contain the same description (A unique identifier designating the company initiating the funds transfer instructions, business transaction or assigning tracking reference identification.) Both data elements contain the same implementation name (Payer Identifier). The TR3 glossary indicates that the Payer Identifier is a number identifying the payer organization. The TRN03 note says it must be a 1 followed by the payer’s EIN (or TIN); however, the BPR10 does not contain this same note. Considering that the TRN segment purpose is to uniquely identify the transaction set and aid in reassociating payments and remittances that have been separated, and that the same originating company is being identified, can the BPR10 and TRN03 values be different from one another or must they be identical within an 835?

Response

nformation reported in the BPR segment of the 835 is to report information about the payment itself, and the banking information of the originator and receiver of the payment.  The TRN segment is used to report information used for reassociating the payment with the 835 remittance advice.  The intent of the two segments is different.
BPR10 is identified within the 835 TR3 as “Originating Company Identifier”, with an implementation name in the TR3 of “Payer Identifier”. It includes a semantic note “BPR10 shall be mutually established between the originating depository financial institution (ODFI) and the company originating the payment.” BPR10 is typically the identifier included in the corresponding ACH transaction identifying the originator of the ACH transaction (Batch Header, Record Type 5, Field Number 5 and positions 41-50 in the NACHA CCD+ transaction).
TRN03 is identified within the TR3 as “Originating Company Identifier”, with an implementation name in the TR3 of “Payer Identifier”. There is no semantic note. There is an element note stating “This must be a 1 followed by the payer’s EIN (or TIN).”

While both elements have the implementation name “Payer Identifier”, there are no notes or explicit requirements within the 835 TR3 that these two elements contain exactly the same value; and, in fact, may not due to the requirement that TRN03 begin with a “1”. The NACHA Operating Rules do not require the Originating Company Identifier in the ACH transaction to be the TIN, so when this value is reflected in BPR10, there may be situations where these values do not match.

DOCUMENT ID
005010X221A1