Payee relationship to customer and accounts

Question

It is interesting that payees are listed as account data in the rules (“stored with the account”).  In our Digital Banking Channel the payees are not related directly to accounts but can be used on any account available in Digital Banking Channel; effectively they are at the customer level.  The standards do not facilitate collection of payees by account.  This implies that the payees are being treated as customer level data (ie payees to be related directly to the customer rather than to one or more accounts) – regardless of which accounts a customer authorised (if any) we would return the same payees. 

Is our modelling correct to relate payees to the customer?

Answer

Under the Designation Instrument this data comes under the heading of account related data in that a customer can only make payments if they have an account.  The Data Standards Body found that different banks treat registered payees differently and many banks hold payees at the customer level.  The APIs were designed to accommodate this as you note.  In this context, the way you are modelling payees is correct.