Changes are coming to The Clearing House's (TCH) RTP® Operating Rules. Starting June 16, 2025, a new framework for “On Behalf Of” (OBO) payments will go into effect, with full compliance required by April 16, 2026.
OBO Payments Defined: RTP payments can now be sent by one party on behalf of another (the actual payer).
Transparency Required: Payment messages must clearly show who’s really paying and who’s receiving the funds—using legal names only.
No Hiding Info: Participants can’t alter payment details to hide identities or make cross-border payments look domestic.
No Nested Payments: Payments can’t involve extra middlemen beyond the payer and payee.
Do Your Homework: You’ll need to vet anyone sending or initiating OBO payments.
Set the Rules: Have internal controls in place for OBO activity.
Report Fraud: Update agreements to ensure fraud gets reported to TCH and the receiving party.
TCH can require a Participant that sends OBO Payments to have a third-party audit for compliance.
Need audit or consultative services relating to your RTP operations? Reach out to SFE's professional services team for a proposal, today.