---
title: "Positive Pay File Policy"
sidebarTitle: "Positive pay files"
description: "How PBI generates, reviews, submits, and monitors positive pay files at client banks to prevent check fraud — including role ownership and exception handling."
icon: "shield-halved"
---

> **For AI agents:** the complete documentation index is at [llms.txt](/llms.txt). Append `.md` to any page URL for its markdown version.

| Field | Value |
|---|---|
| **Owner** | Accounting Leadership Team |
| **Department** | Accounting / Accounts Payable / Payroll |
| **Effective date** | June 1, 2025 |
| **Last updated** | May 7, 2025 |
| **Scope** | Processing and submitting positive pay files to client banks. Applies to all PBI clients that issue paper checks from operating or payroll bank accounts, require positive pay uploads to their financial institution, and use R365, Intacct, or ProWork to generate the files. |
| **Source** | `Accounts Payable Department/3. Payment Processing/Positive Pay File Policy.docx` |

<Info>
  This is a **policy**. Positive pay is a fraud control with hard daily bank deadlines — missing one can allow a fraudulent check to clear.
</Info>

## Definitions

| Term | Meaning |
|---|---|
| **Positive pay** | A fraud prevention system that matches checks presented to a bank against a list of issued checks provided by the account holder. |
| **Check register** | A report or file listing check number, amount, date, and payee. |

## Roles and responsibilities

| Role | Responsibility |
|---|---|
| **AP Staff** | Process AP payments, generate positive pay files, and coordinate with the Staff Accountant. |
| **Payroll CSM** | Process payroll payments, generate positive pay files, and coordinate with the Staff Accountant. |
| **Staff Accountant** | Review positive pay files, ensure bank formatting compliance, submit for upload, and handle exceptions as alerted. |
| **Client Manager** | Confirm process compliance, coordinate bank requirements with the client, and resolve escalations. |

## Tools used

| Tool | Used for |
|---|---|
| **Sage Intacct / R365** | Check creation and the AP payment approval process |
| **ProWork** | Check creation and the payment approval process for payroll |
| **Excel / Notepad** | The positive pay file itself, for loading into the bank |
| **Client bank portals** | File submission and exception handling |

## Preconditions

Confirm all three before running this process for a client:

- The client has positive pay service activated at their bank.
- The Staff Accountant has access to the client's banking portal.
- Format requirements from the client's bank are documented in the client perm file.

## Workflow

<Steps>
  <Step title="[AP Staff] Generate and review the AP positive pay file">
    Once accounts payable payments are processed in Intacct or R365, generate the positive pay file and review it for accuracy.

    Confirm each of these matches what was processed in the accounting software:

    - Check numbers
    - Vendor name
    - Amounts
    - Dates
  </Step>

  <Step title="[Payroll CSM] Generate and review the payroll positive pay file">
    For payroll checks, generate the check register within ProWork for any employees being paid by check, then generate a positive pay file from ProWork.

    Review these fields against what was processed in ProWork:

    - Check numbers
    - Employee name
    - Amounts
    - Dates
  </Step>

  <Step title="Save the file to the client's SharePoint">
    Both AP Staff and the CSM save the completed positive pay file in the client's SharePoint, in the designated folder.
  </Step>

  <Step title="Submit the file to the bank">
    Handoff differs by payment type:

    - **AP Staff** load AP files to the bank **as soon as they are generated**.
    - **Payroll CSMs** inform the Staff Accountant that the file is ready. The Staff Accountant — at their earliest convenience and before the end-of-day deadline — opens the file, reviews it to confirm the CSM's review, then logs into the client's bank portal using secured credentials.

    Submit the file in the appropriate screen within the client's bank portal.
  </Step>

  <Step title="Save confirmation of submission">
    Once submitted, save confirmation of the submission to the client's SharePoint in the designated space.

    **Expected outcome:** every check issued that day appears on the bank's issued-check list, and a dated submission confirmation is filed.
  </Step>

  <Step title="[Staff Accountant] Monitor and clear exceptions">
    The Staff Accountant is the designated individual responsible for monitoring and clearing any exceptions.

    Clear exceptions at your earliest convenience and **no later than the banking institution's daily deadline**.

    <Warning>
      Exception notification timing varies by client and bank — morning, noon, or end of day. Document the standard notification timing and the deadline for each institution, plus each bank's policy for exceptions that are not cleared by the deadline. **Most banks clear uncleared exceptions automatically**, which is exactly the outcome positive pay exists to prevent.
    </Warning>
  </Step>
</Steps>

## Coverage requirements

Positive pay has a daily deadline that does not pause for PBI's calendar.

<AccordionGroup>
  <Accordion title="PBI holidays that are not banking holidays">
    The Client Manager coordinates with the Staff Accountant and client to ensure coverage for any positive pay exceptions. **The preference is for the client to clear exceptions** if that day is not a holiday for them.
  </Accordion>
  <Accordion title="PBI vacation and time off">
    Coverage must be arranged for any Staff Accountant who is out of office. If special access is needed so another individual can provide coverage, the Client Manager, Staff Accountant, and client must coordinate that **proactively** — not on the day it's needed.
  </Accordion>
</AccordionGroup>

## Common issues and resolutions

| Issue | Resolution |
|---|---|
| **File rejected by bank** | Review the format, cross-check against the bank template, and reformat using the macro. |
| **Missed upload deadline** | Notify the Client Manager immediately and request a bank exception if possible. |
| **Missing confirmation** | Check bank portal history, re-download, and attach to the file folder. |

### Bank exceptions

When the bank flags payments as potentially fraudulent, the Staff Accountant reviews the issue. Common causes:

- The check has already previously cleared
- Payee name discrepancy
- Mismatched check number
- Incorrect account
- Date issues
- Someone manually edited a check after the positive pay file went to the bank

## Related documents

- [Day-to-day AP transactions in Sage Intacct](/internal/sops/accounting/ap/intacct-ap-transactions) — printing and confirming the check run that feeds this file
- [Stuffing and mailing checks](/internal/sops/accounting/ap/stuffing-checks) — physical handling after printing
- [Bank (NACHA) file payment processing policy](/internal/sops/accounting/ap/nacha-bank-file-policy) — the equivalent control for electronic payments