유럽의 단일유로화지급지역(SEPA)과 미국의 자동교환정산원(ACH)간의 비교연구

A Comparative Assessment of Automated Clearing House(ACH) of America and SEPA of EU -Focus on a Risk Management Policy and Key Features-

This paper discusses on the electronic payment system which EU and America have and operate at present. Specifically ACH(Automated Clearing House)which a computer-based national counter checking system, supporting both debit and credit transfer and located in America was compared with SEPA(Single Euro Payment Area). SEPA process started in 1999 as Single Euro Payment Area. It has now reached the final migration phase for two SEPA payment instruments. By 1 February 2014, credit transfer and direct debits in the euro area will be carried out in accordance with the technical requirements. I used Regulation E, and Operating Circular as tools to analyze ACH. I also adapted ACH rules which NACHA legislates a self rules, while I made good use of the payment service directive and SEPA migration end-date regulation(Regulation EC 924/2009, EC 260/2012) using most important law system for information about SEPA. I also referred to the SEPA Credit Transfer Scheme Rulebook as well as SEPA Direct Debit Scheme Rulebook to rule concerned parties who participated in SEPA. Thus in this article, first of all, I presented background and legal foundation of the SEPA of the EU and ACH of North America. Second, I analyzed the distinguishing features of the payment systems and mechanisms for both systems including participation methods in such payment systems. Third, I focused on the operation policy and the allocation of risk of loss caused by ambiguous payment orders and technology errors of system. Lastly, In order to develop electronic payment system, I suggested policy proposals together with conclusion.