(TPG) - USER MANUAL - Santa Barbara Tax Products Group REFUND PROCESSING PROGRAM - TPG for Tax Pros
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Santa Barbara Tax Products Group
(TPG)
REFUND PROCESSING
PROGRAM
USER MANUAL
2019 User Manual, 2019-1A, January 2019Contents
IMPORTANT NOTE REGARDING PROGRAM AVAILABILITY ...................................................................................................................... 4
PROGRAM OVERVIEW............................................................................................................................................................................... 4
A) TAXPAYER INSTRUCTIONS TO IRS ............................................................................................................................................................... 4
B) FREE IRS E-FILE OPTION ......................................................................................................................................................................... 4
C) REFUND PROCESSING .............................................................................................................................................................................. 5
D) ABOUT PREPARER FEES ........................................................................................................................................................................... 5
E) BALANCE DUE RETURNS........................................................................................................................................................................... 5
THE PROGRAM ENROLLMENT PROCESS ................................................................................................................................................... 6
A) IRS ENROLLMENT AND EFIN/PTIN APPROVAL ............................................................................................................................................ 6
B) TPG ENROLLMENT APPLICATION AND MANDATORY COMPLIANCE TRAINING ..................................................................................................... 6
C) TPG FINANCIAL SERVICES AGREEMENT (FSA) ............................................................................................................................................. 7
D) ACTIVATION OF NEW EROS ..................................................................................................................................................................... 8
E) OFFICE RECORD SETUP ............................................................................................................................................................................ 8
F) CONFIRMING ENROLLMENT AND VALIDATING OFFICE RECORDS AND SETUP ....................................................................................................... 9
G) ERO DISQUALIFICATION AND SUSPENSION.................................................................................................................................................. 9
SUPPLIES, MARKETING MATERIALS, MAILERS AND SHIPPING ................................................................................................................ 9
A) STANDARD SUPPLIES ............................................................................................................................................................................. 10
B) MARKETING MATERIALS ........................................................................................................................................................................ 10
DESCRIPTION OF REFUND PROCESSING SERVICES ................................................................................................................................. 11
A) IRS DIRECT DEPOSIT AND IRS PAPER CHECK ............................................................................................................................................. 11
B) IRS REQUIRED 7216 CONSENT FORMS .................................................................................................................................................... 11
1) CONSENT TO USE TAX RETURN INFORMATION .......................................................................................................................... 11
2) CONSENT TO DISCLOSE TAX INFORMATION ............................................................................................................................... 12
C) REFUND TRANSFER (RT) ........................................................................................................................................................................ 12
1) Procedure for Offering a Refund Transfer ................................................................................................................................... 12
2) State Refund Transfer (SRT) ........................................................................................................................................................ 13
D) FEE COLLECT (FC) PAYMENT OPTIONS ..................................................................................................................................................... 13
1) Pay By Refund ............................................................................................................................................................................. 13
2) Pay by ACH Direct Debit .............................................................................................................................................................. 13
3) Procedure for Offering a Fee Collect ........................................................................................................................................... 14
E) TAXPAYER ADVANCE............................................................................................................................................................................. 14
F) TAXPAYER IDENTIFICATION ..................................................................................................................................................................... 15
DISBURSEMENT METHODS ..................................................................................................................................................................... 15
A) SITE PRINTED CASHIER’S CHECK .............................................................................................................................................................. 15
1) Description of the Check and Check Stub .................................................................................................................................... 16
2) Check Shipments ......................................................................................................................................................................... 16
3) Check Storage and Security ......................................................................................................................................................... 17
4) Check Handling Exceptions.......................................................................................................................................................... 17
5) Forgery Procedures ..................................................................................................................................................................... 19
6) Power of Attorney ....................................................................................................................................................................... 19
7) Good Funds Check Cashing Agreement ....................................................................................................................................... 20
B) REMOTE CHECK PRINTING ...................................................................................................................................................................... 21
C) ACH DIRECT DEPOSIT ........................................................................................................................................................................... 21
D) WALMART MONEYCARD (IF OFFERED) .................................................................................................................................................... 22
1) How to Participate ...................................................................................................................................................................... 22
2019 User Manual, 2019-1A, January 2019 2 of 362) Procedure for Offering the Prepaid Card..................................................................................................................................... 22 E) WALMART DIRECT2CASH....................................................................................................................................................................... 23 OFFICE PROCEDURE AND PRACTICE ....................................................................................................................................................... 23 A) BEST PRACTICE GUIDE AND USER MANUAL ............................................................................................................................................... 23 B) ERO CHECKLIST ................................................................................................................................................................................... 23 C) STATE REGULATORY REQUIREMENTS/STATE DISCLOSURES ........................................................................................................................... 23 D) OFFICE SETUP...................................................................................................................................................................................... 23 E) IDENTIFYING THE TAXPAYER .................................................................................................................................................................... 24 F) PRODUCT SELECTION AND IRS RULE 7216 ................................................................................................................................................ 28 G) DISCLOSING PREPARER FEES................................................................................................................................................................... 28 H) REFUND TRANSFER (RT) APPLICATION AND AGREEMENT. ............................................................................................................................ 29 I) FEE COLLECT (FC) AGREEMENT ................................................................................................................................................................ 30 J) FRAUD PREVENTION .............................................................................................................................................................................. 30 K) PREPARER FEE PAYMENT INFORMATION ................................................................................................................................................... 32 L) FORMS TO DOWNLOAD .......................................................................................................................................................................... 33 TAX PREPARER/ERO COMPLIANCE MONITORING ................................................................................................................................. 34 A) MONITORING PROGRAMS ...................................................................................................................................................................... 34 B) ERO CORRECTIVE ACTION...................................................................................................................................................................... 34 CUSTOMER SERVICE SUPPORT................................................................................................................................................................ 35 A) CONTACT INFORMATION........................................................................................................................................................................ 35 B) TPG INTERNET SUPPORT ....................................................................................................................................................................... 36 2019 User Manual, 2019-1A, January 2019 3 of 36
IMPORTANT NOTE REGARDING PROGRAM AVAILABILITY
Please note that this User Manual provides information on our entire product line. You may not be
eligible for all products or services described herein and the products and services described may not
be available through the software provider you work with. Please check with your software provider
as to the availability of a particular Program, product or service and check with TPG for eligibility.
PROGRAM OVERVIEW
Santa Barbara Tax Products Group, LLC (“TPG”) offers tax refund processing services using the banking
services of Civista Bank (“Bank”). TPG offers a Refund Transfer service (“RT” or “RT product”) and a Fee
Collect service (“FC” or “FC product”), and makes available tax refund advance products offered by a
third party refund advance provider, to tax preparers and taxpayers. The RT, FC and refund advance
products offered or made available by TPG for particular transmitters or tax preparers are referred to in
this Manual individually or collectively as the “Program.” TPG provides refund processing services and
customer support for the Program and has established Program guidelines, and is responsible for the
Program’s compliance with applicable law. TPG is a third party processor with respect to the refund
processing services it performs for the Program.
TPG offers refund processing services to taxpayers who:
• E-file their tax return, and
• Are owed a tax refund by the IRS.
A) Taxpayer Instructions to IRS
In order to apply for an RT or FC, the taxpayer must include on the tax return an instruction to
the Internal Revenue Service (“IRS”) and/or state tax authority to deposit the taxpayer’s tax
refund to a temporary account at the Bank established by TPG on the taxpayer’s behalf. When
the tax refund is deposited into the temporary account by the IRS or state tax authority, TPG is
able to make deductions from the refund on behalf of the taxpayer in order to pay for services
such as income tax preparation. This allows the taxpayer to have their taxes prepared without
having to pay preparer fees at the time the tax return is prepared. Once all fees and charges
have been paid, TPG will disburse the remainder of the taxpayer’s deposit account using the
disbursement method selected by the taxpayer and close the temporary account. At that time,
the services of the tax preparer will be completed.
B) FREE IRS e-File Option
A taxpayer does not have to apply for an RT or FC or utilize TPG’s refund processing services in
order to e-file their tax return. If a taxpayer files their tax return electronically, they can receive
a refund check directly from the IRS in 21 days from the time their tax return is filed or the IRS
can deposit their refund directly into their bank account in less than 21 days from the time the
tax return is filed. When the tax preparer uses the tax preparation software to calculate a
refund, the tax preparer should advise the taxpayer about the benefits of electronically filing a
tax return and about the various options for receiving a refund including the IRS “FREE” options.
2019 User Manual, 2019-1A, January 2019 4 of 36There is no charge by the IRS for this service but the IRS cannot deduct and pay tax preparer fees
from the refund on behalf of the taxpayer. If a taxpayer chooses this option, the tax preparer
will have to collect tax preparation fees directly from the taxpayer at the time their taxes are
prepared.
C) Refund Processing
In order to participate in a TPG Program, the tax preparer must use tax preparation software
that integrates and supports TPG’s Program. If the client chooses to use TPG’s refund processing
services, the software will automatically populate the applicable TPG product application using
information keypunched during the preparation of the tax return. The product application and
any supporting disclosures are printed along with a copy of the tax return. The taxpayer signs a
copy of TPG product documentation which the tax preparer keeps in its files, and the tax
preparer pushes a button which causes the tax return and the product application to be
electronically filed through the software provider. A copy of the tax return is transmitted by the
software provider/transmitter to the IRS and to TPG. A copy of the product application is
transmitted to TPG once the IRS has acknowledged the receipt of the tax return. When the IRS
funds the return, TPG transmits a disbursement authorization back through the software
provider/transmitter to the tax preparer. In most cases, the tax preparer will print a cashier’s
check for the taxpayer.
Note: Tax preparers who work with a service bureau may have their software provided by the
service bureau. Or, the service bureau may file the tax return and TPG product application on
behalf of the tax preparer depending on the contractual relationship the tax preparer has with
the service bureau.
D) About Preparer Fees
It is important to recognize that tax refunds are not guaranteed. On an average, about 8% of IRS
refunds are not funded. The reasons for non-funding are varied and may include IRS offsets for
outstanding taxes, government agency debt, denial of Earned Income Credit (“EIC”) claims, or
fraud. When a TPG product is selected and the IRS does not deposit a refund with TPG, the tax
preparer and TPG do not receive payment of their fees. Tax preparers should consider this when
setting a price for their services.
Preparer’s fees are deposited by TPG directly to TPG account of the tax preparer or service
bureau. Fees are paid within 24 hours of receipt of IRS funding unless delayed or frozen
pursuant to the Financial Services Agreement (described below).
Tax preparers must not charge higher tax preparation fees based on whether or not a taxpayer
chooses an RT, FC or refund advance product. Fees should be reasonable and transparent,
meaning that taxpayers should know exactly what fees will be charged for each product or
service and a written fee disclosure needs to be provided from the tax preparer to the taxpayer.
E) Balance Due Returns
In instances where there is a balance due on a tax return, no refund is due and the taxpayer will
have to find a way to pay both their tax liabilities and their preparer for their time in preparing
their tax return. In this case, TPG will process a credit card payment or make an authorized
direct debit of the taxpayer’s personal bank account in the event the taxpayer does not have
immediate funds.
2019 User Manual, 2019-1A, January 2019 5 of 36THE PROGRAM ENROLLMENT PROCESS
In order to participate in the Program, a tax preparer must have:
A valid IRS-issued Electronic Filing Identification Number,
A valid IRS-issued Preparer Tax Identification Number (“PTIN”) for the EFIN holder and
every tax preparer that works under that EFIN
Purchased software from a participating transmitter/software provider,
Submitted a program enrollment application via the transmitter/software provider,
Reviewed and agreed to the Financial Services Agreement, and read and understood the
User Manual, Best Practice Guide, Compliance Memo and ERO Checklist,
Completed the online training compliance module and posted a passing score and maintain
documentation of passing compliance training for all PTIN holders under their EFIN.
Note: Tax preparers who work with a service bureau 1 must consult the service bureau
concerning the enrollment process and any additional requirements.
A) IRS Enrollment and EFIN/PTIN Approval
Before a tax preparer can file tax returns electronically, it must apply to the IRS for an Electronic
Filing Identification Number (“EFIN”). Along with the application for an EFIN, the tax preparer
must provide the IRS with a copy of their fingerprints. The IRS runs suitability checks on the tax
preparer, including a criminal background check and credit history. IRS rules also require that
the tax preparer complete continuing education and obtain a PTIN or Preparer Tax Identification
Number. If the tax preparer passes the suitability checks and otherwise complies with IRS
preparer registration requirements, they are issued an EFIN and a PTIN and notice is sent to the
preparer by way of an EFIN/PTIN approval letter. These notices give the EFIN and PTIN number
and state that the preparer is accepted as an Electronic Return Originator (“ERO”) for the
purpose of electronically filing income tax returns with the IRS. TPG requires a valid EFIN and
PTIN for each office that files tax returns and submits applications for TPG products and a PTIN
for every tax preparer who works under that EFIN. The ERO must be prepared to provide proof
of the EFIN and PTIN registration to TPG upon request. If the ERO is no longer able to produce an
EFIN approval letter, TPG will accept a faxed copy of the approved EFIN application page from
the IRS website. The ERO may have to obtain a PIN from the IRS to access this webpage. The
EFIN is a critical part of the ERO’s office setup and plays a critical part in the ability of the
transmitter and TPG to process and track the returns and TPG product applications filed. It is
important that you do not allow the unauthorized use of your EFIN.
B) TPG Enrollment Application and Mandatory Compliance Training
TPG has relationships with a number of electronic filing providers (“EFPs”). If an ERO uses one of
these EFPs (also known as software providers), the EFP will provide the ERO with a TPG
enrollment application. The enrollment application will be presented in electronic format and
requires an electronic signature. The information required in this form includes the ERO’s
1
Service Bureaus are resellers of software who often provide startup expertise to new offices. They provide hands on support that the
Electronic Return Originator (“ERO”) cannot get from the transmitter. They often provide specialized training with respect to tax
preparation and TPG products. Service bureaus bill the ERO on a per return basis for this help. TPG facilitates payment of the
service bureau on behalf of the ERO by making payment to the service bureau from the preparers’ fees.
2019 User Manual, 2019-1A, January 2019 6 of 36business name, physical address, shipping address, telephone numbers, EFIN, PTIN, social
security number, EIN, email address, electronic filing history and an authorization to run a credit
report. The EFP may provide TPG with an electronic record of the application information or fax
the form to TPG, keeping the original on file. The information from the fax or electronic record is
used to set up an enrollment record at TPG. Tax preparers should review their enrollment
record information on TPG’s website as soon as they have registered through the EFP. The
enrollment record is updated daily at TPG.
MANDATORY ERO TRAINING: TPG requires that each EFIN holder completes the
compliance training module located on www.sbtpg.com. The TPG enrollment application
will not be activated until this process is complete and fees will be withheld. The ERO
should make sure that each tax preparer in their office passes the compliance training and
receives a completion certificate.
Note 1 for ERO: EIN/SSN - In the event that TPG needs to report 1099-Misc income on
behalf of the ERO, TPG will use the business or contact name associated with the EIN/SSN
on the TPG enrollment application. The ERO should ensure that the contact information in
the enrollment record is the same as the name associated with that EIN/SSN at the IRS. In
order to report 1099-Misc income, TPG will use the EIN and company name in the
enrollment record. If the EIN is not present in the record, TPG will use the SSN and
business owner’s name. The ERO should come to the TPG website and confirm or update
the enrollment record to avoid misreporting to the IRS.
Note 2 for ERO: Email Address - Email address is now required from each ERO as it will be
the primary method used by TPG to communicate any changes in requirements,
procedures, and other important information. Some of these communications may be
directed to all EROs offering TPG products while other emails may be directed to and
pertaining to specific offices only. The ERO should make certain that an email address that
is constantly reviewed is entered in the TPG enrollment application as it will be each
office’s responsibility to read the email communications and ensure its receipt. The email
address will not be shared and will not be used for any other purpose.
C) TPG Financial Services Agreement (FSA)
As part of the enrollment process, each ERO must consent to the TPG Financial Services
Agreement (“FSA”). The FSA is a contract between the ERO, TPG and the Bank. The FSA sets
forth the responsibilities of the ERO under the Program. Under the terms of the FSA, TPG can
suspend an ERO from the program in the event the ERO does not perform in accordance with
procedures set forth in the FSA, TPG User Manual, or Best Practices Guide. It provides that an
ERO can be suspended if they are suspected of fraud, if the ERO’s performance shows a
significant number of unfunded transactions, or if the ERO engages in what TPG considers
unacceptable practices. The FSA also authorizes TPG to freeze, reverse or debit Automated
Clearing House (“ACH”) payments of an ERO’s tax preparation and electronic filing fees
• that are associated with tax returns that are in dispute or with activity that TPG
considers fraudulent or suspicious;
• that could result in losses to TPG;
• to ensure completion of compliance requirements or corrective action; or
• to reimburse TPG for payments to taxpayers due to the ERO’S noncompliance.
2019 User Manual, 2019-1A, January 2019 7 of 36Frozen, reversed or debited tax preparation and electronic filing fees will be released or paid to
the ERO upon the ERO’s completion or satisfaction of compliance requirements or corrective
action, or payment to taxpayers, as applicable; provided, however, that after one year frozen,
reversed or debited fees retained by TPG shall be forfeited to TPG or posted against losses
accrued by TPG through the ERO’s office or EFIN.
Typically, the FSA is provided to the ERO in an electronic format as part of the EFP’s online TPG
enrollment process. Once the EFP forwards an electronic enrollment record to TPG and TPG
approves the enrollment, TPG emails a confirmation copy of the FSA to the ERO along with an
activation letter. The FSA is also available as a download on www.sbtpg.com. The agreement is
irrevocably confirmed when the ERO processes their first refund through TPG.
It is critical the ERO reads and understands the FSA terms, conditions and requirements. It is also
important to read the following materials in order to gain an understanding of the scope of best
practices that TPG expects from each tax preparer:
• The User Manual
• Best Practices Guide
• ERO Checklist
• ERO Compliance Memo
• ERO Compliance Training
D) Activation of New EROs
The enrollment status is “pending” until activated. The ERO is activated once the following takes
place: a completed enrollment record has been received from the EFP; the ERO has paid the
software fees and fulfilled all the enrollment requirements of the EFP and TPG; and the ERO has
passed the risk analysis review. TPG mails the ERO an activation letter, the FSA, and other
important season updates or notices. As part of the enrollment process, the ERO is referred to
www.sbtpg.com to review a copy of the FSA, User Manual, ERO Checklist, Compliance Memo,
Best Practices Guide, and Online Compliance Training Exam. The activation letter includes a link
to TPG’s website where the ERO can access these important compliance documents, reports and
forms. The ERO should retain the activation letter. The activation of the enrollment record also
creates a shipping record for supplies. The ERO is expected to read and be familiar with the
Best Practices Guide, User Manual, FSA, ERO Checklist and Compliance Memo.
Renewals/Pre-Approvals: Prior year TPG clients in good standing (i.e. EROs without open
corrective action items) may receive an enrollment letter indicating they are automatically
accepted into TPG’s program. This enrollment letter should be retained for further reference.
Although the ERO might receive this letter, they still need to complete the enrollment process
with the EFP.
E) Office Record Setup
Before TPG can process fees on behalf of an ERO, TPG must receive an office record from the
EFP through whom the ERO is filing. Some EFPs create the office record on behalf of the ERO and
transmit the record directly to TPG. Whereas other software packages require the ERO to
complete the office setup in the software and the software will generate the office record on
behalf of the ERO which is transmitted to TPG. If the office record is not set up correctly, TPG will
be able to process a refund submitted by an ERO but TPG will not be able to process the ERO’s
2019 User Manual, 2019-1A, January 2019 8 of 36fees until the office record is set up correctly. It is the EROs responsibility to make sure the
office record is set up correctly and that the ERO is receiving fees. TPG will not be responsible
for misdirected fees that result from the failure of the ERO or their transmitter to provide TPG
with a correct office record. Routing transit number (“RTN”) and the depositor account number
(“DAN”) information will remain unlocked until the first day of IRS e-filing. After this date, RTN or
DAN changes MUST be done through TPG. The ERO must fax their IRS EFIN Approval Letter, and
a request to unlock the account information to 877-901-5646. If the IRS Approval Letter is not
available, please submit an unexpired government-issued photo ID (i.e. Driver’s License or
Passport). TPG does not accept credit cards as forms of ID. Once TPG has unlocked the RTN/DAN
field, a representative will contact the ERO and let them know it is ready to accept the changes
by resubmitting their office record with the new bank information via the transmitter software.
Each ERO should run a Fees Paid report on the TPG website after processing a TPG product to
ensure that the correct fees are being paid. All record changes must be made through the EFP.
F) Confirming Enrollment and Validating Office Records and Setup
The enrollment status of the ERO can be checked via TPG’s website at www.sbtpg.com. It is
important that the ERO confirms their office information including SSN, EIN and email address
which are required fields. The ERO’s enrollment status can be checked without using a PIN. The
enrollment status is indicated as “pending” until confirmation is received from the EFP that the
software fees have been paid. If the status is indicated as “active”, the ERO is approved to file
TPG products but their office record must still be submitted (see above). An activated ERO can
use their PIN to log in and validate the office record and setup. An activated ERO can make
changes to the enrollment record through the website but all office record changes must be
made through the ERO’s EFP.
G) ERO Disqualification and Suspension
TPG monitors for patterns of unfunded accounts, excessive fees, and the profitability of EROs for
the purpose of detecting the presence of fraud, lack of due diligence, poor office procedure that
can result in losses or unacceptable practices that could be considered overreaching or
predatory. If TPG receives a high number of customer complaints concerning a particular ERO or
if it comes to the attention of TPG that an ERO is operating in violation of the law, in breach of
TPG’s FSA, committing fraud in the conduct of their business, engaging in unacceptable practices
or having a significant negative impact on profitability, TPG may immediately suspend the ERO
from the Program in accordance with the FSA or restrict the ERO to TPG printed checks. Prior to
suspending or restricting the ERO, TPG will attempt to contact the ERO to discuss the situation. If
the situation cannot be resolved to the satisfaction of TPG, the ERO’s EFIN record will be
inactivated at TPG and the ERO’s transmitter will be notified of the suspension.
SUPPLIES, MARKETING MATERIALS, MAILERS AND SHIPPING
The supplies the ERO receives depends on the Program they are registered in. If the program allows for
disbursement by check, they will be shipped check stock. If the program allows for disbursement by card
and the ERO opted into that Program, they will be shipped card stock.
2019 User Manual, 2019-1A, January 2019 9 of 36A) Standard Supplies
Cashier’s Checks: The initial supply shipment sent to most EROs will include cashier’s check
stock. Other important documents such as a Good Funds Check Cashing Agreement, a check log,
and a supply order form may be included in the shipment or will be available for download from
www.sbtpg.com located in the Downloadable Forms section. If the ERO is new to TPG, the initial
order will generally include 50 checks. If the ERO is a returning ERO, the volume of checks will
equal their prior year’s volume, plus 25%. If the ERO works with a service bureau, the service
bureau may provide supplies directly to the ERO. Additional supplies can be ordered on the TPG
website (if applicable) or through the ERO’s Service Bureau. These supplies are shipped free
using two-business day delivery. The ERO must pay the shipping charges for any next day
shipments. If offered, prepaid cards will be shipped with the initial supply shipment if the ERO is
approved or opts in to the prepaid card Program in a timely manner (see Card Shipments under
Disbursement Methods section).
B) Marketing Materials
Marketing materials must be special ordered directly through TPG. Marketing materials include
banners, posters, postcards, mobiles, and brochures. Examples of the marketing materials
available can be seen on TPG’s website and can be ordered online. All marketing materials
provided by TPG may only be used for the purposes originally intended.
If the ERO intends to develop or has developed their own marketing materials, whether online
or in print, the materials must adhere to TPG’s marketing standards and be approved in writing
by TPG prior to use. All marketing materials provided by TPG may only be used for the purposes
originally intended. TPG’s logos and trademarks are copyrighted materials and shall not be used
except as authorized by or with the express written permission of TPG.
The ERO is restricted from using misleading statements about any of TPG’s products in their
advertising or representation of the products, such as:
“Instant tax money” or “Get your refund fast” or “Rapid refund”
or statements that TPG products are offered by someone other than TPG.
The ERO must avoid product confusion. If they have questions or concerns in reference to marketing
materials and their compliance to TPG’s guidelines, please call 800-779-7228 and ask for the Marketing
Department.
The TPG marketing department has worked hard to create marketing campaigns that comply with
consumer protection laws. The ERO can count on TPG to provide approved marketing materials. TPG has
marketing materials available for each office, so the ERO can easily ensure materials are up to date.
UDAAP COMPLIANCE
“UDAAP,” stands for “unfair, deceptive, or abusive acts or practices.” Federal financial regulators
have included unfair, deceptive and abusive practices within regulatory examinations and
enforcement actions. The following defines unfair, deceptive, and abusive practices:
An act or practice is unfair when:
It causes or is likely to cause substantial injury to consumers;
2019 User Manual, 2019-1A, January 2019 10 of 36The injury is not reasonably avoidable by consumers; and
The injury is not outweighed by countervailing benefits to consumers or to competition.
An act or practice is deceptive when:
The act or practice misleads or is likely to mislead the consumer;
The consumer’s interpretation is reasonable under the circumstances; and
The misleading act or practice is material.
An act or practice is abusive when it:
Materially interferes with the ability of a consumer to understand a term or condition of a
consumer financial product or service; or takes unreasonable advantage of –
A consumer’s lack of understanding of the material risks, costs, or conditions of the
product or service;
A consumer’s inability to protect his or her interests in selecting or using a consumer financial product or
service; or
A consumer’s reasonable reliance on a covered person to act in his or her interests.
The ERO is expected to be familiar with UDAAP compliance as set forth above and must make
sure that their advertising and customer interactions are UDAAP compliant.
DESCRIPTION OF REFUND PROCESSING SERVICES
A) IRS Direct Deposit and IRS Paper Check
IRS direct deposit and IRS paper check are not TPG’s financial products but they are important FREE
alternatives that the ERO must explain to the taxpayer, prior to explaining any TPG services.
Taxpayers who file their tax return electronically can choose to have the IRS deposit their refund
directly to their bank account or have the IRS mail a check to the address on their tax return. There
is no charge to the taxpayer for this service. A direct deposited refund will arrive in less than 21 days
(similar to the time it takes for TPG to process the refund). An IRS check will take 2-3 weeks to
arrive. The difference between the IRS products and TPG services is that the IRS cannot make
deductions from the refund to pay third party fees on behalf of the taxpayer. If the taxpayer
chooses IRS refund processing, the taxpayer must pay tax preparation fees out of pocket at the time
their taxes are prepared. Again, the ERO should explain these no-cost alternatives to the taxpayer
before offering TPG’s products. These alternatives are also listed on the front page of the RT
Application and Agreement.
B) IRS Required 7216 Consent Forms
The IRS has implemented IRS Rule 7216 to mandate that tax preparers obtain TWO (2) written
consents from the taxpayer to use and disclose their tax information. These are very specific
forms with very specific requirements as to timing and content:
1) CONSENT TO USE TAX RETURN INFORMATION. This form is required to allow the
tax preparer to use the taxpayer’s tax information to determine if TPG products are
available to the taxpayer. This form is provided to you as a courtesy on the TPG website,
under the Downloadable Forms section. The ERO should print copies of this form for use
2019 User Manual, 2019-1A, January 2019 11 of 36during the tax season if the forms are not provided through the software. The ERO is
required to provide to each taxpayer prior to discussing any TPG products. The ERO should
have each taxpayer sign the consent form as soon as a tax refund amount is established. If
Taxpayer Advance is being offered, a separate Consent to Use for Taxpayer Advance is
required, in addition to the standard Consent to Use.
2) CONSENT TO DISCLOSE TAX INFORMATION. This form is required to allow the tax
preparer to disclose the tax return information to a third party (i.e., TPG) if a TPG product
is selected. This consent form will print out with the Program documentation. The ERO is
required to have each taxpayer sign this document before the taxpayer signs their tax
return, and before submitting the tax return. If Taxpayer Advance is being offered, a
separate Consent to Disclose for Taxpayer Advance is required, in addition to the
standard Consent to Disclose.
Both of these consent forms are provided to the ERO as a courtesy by TPG. It is highly
recommended that the ERO seek professional counsel as to their legal sufficiency as a tax
preparer. Also, the transmitter may provide the ERO with different forms. Provide a copy of both
the signed consents to the taxpayer.
C) Refund Transfer (RT)
A Refund Transfer (“RT”) is not a loan, it is a refund processing service provided through TPG. When
the taxpayer selects an RT, they direct the IRS to deposit their tax refund into a temporary account
at the Bank. When the Bank receives the IRS refund (less than 21 days from the filing date), TPG
makes deductions from the refund to pay the ERO’s fees and TPG fees. The balance of the refund is
then disbursed to the taxpayer by way of a check printed in the ERO’s office (unless another
disbursement method is chosen). TPG receives deposits from the IRS on a daily basis but primarily
one major deposit each week on Wednesday. Upon IRS funding, TPG will generate check print
authorizations for all the ERO’s clients that funded in that cycle. Large volume offices should
prepare for the high volume of foot traffic that might occur on a single day as RT customers come in
to pick up their checks.
If TPG does not receive an IRS refund on behalf of a taxpayer who selects a TPG product, no fees –
including the tax preparation fees charged by the ERO – will be paid. In the case of such unfunded
returns, the ERO must collect their fees directly from the taxpayer. The ERO can check on the status
of a taxpayer’s IRS refund using the TPG website. A small percentage of refunds are funded one
week past their expected funding date. If the refund is not received more than one week past the
expected IRS funding date, the ERO should contact the taxpayer directly to collect the preparer
fees.
1) Procedure for Offering a Refund Transfer
Once the RT option is selected, the software will print out all the required documentation.
The taxpayer must sign all documentation, including the IRS 7216 Consent Forms before
the ERO transmits the tax return and the RT request. The documentation will consist of
the RT Application and Agreement, an RT Fee Disclosure form, and the 7216 Use and
Disclosure Consent forms. The ERO MUST provide a copy of the RT Application and
Agreement, Fee Disclosure, Bank Privacy Policy and the 7216 Use and Disclosure Consent
forms to the taxpayer and also retain copies of this documentation. Copies of this
documentation will be asked for if your office is reviewed by TPG. You will be subject to
2019 User Manual, 2019-1A, January 2019 12 of 36corrective action, including inactivation from the program, if you are unable to produce
copies of signed documentation when asked.
2) State Refund Transfer (SRT)
If the taxpayer is interested in this option, TPG will process the taxpayer’s state refund
transfer (“SRT”) in the same way the federal RT is processed. If an SRT is filed with a federal
RT, make the appropriate indication in the software. On the TPG RT Application and
Agreement, the SRT has its own check box. It must be checked if the SRT is filed. The SRT will
be disbursed using the same method used for disbursing the federal RT. If a state refund is
received before a federal refund, all fees except the fee for processing the second refund
will be deducted from the state refund.
D) Fee Collect (FC) Payment Options
(Check with your software provider for availability. You cannot offer the Fee Collect Program
and the traditional RT program out of the same office.)
The Fee Collect program provides two options for paying tax preparation fees: 1) pay by refund (the
so-called “Fee Collect” method), or 2) pay by ACH direct debit of the taxpayer’s bank account (“Fee
Pay”). The integration of the Fee Collect or Fee Pay options in participating tax preparation software
packages allows for simple payment processing and management of accounts receivable. All fees
other than the fee charged by the ERO for preparing the taxes are deducted and paid from the tax
preparer fee.
1) Pay By Refund
When the taxpayer chooses to pay their tax preparer fees via the refund, they direct the IRS
to deposit their tax refund into a temporary account at Bank. When Bank receives the IRS
refund (less than 21 days from the filing date), TPG makes a deduction from the refund to
pay the ERO’s fees. The balance of the refund is then disbursed to the taxpayer by way of an
ACH direct deposit to the account designated by the taxpayer and ERO. Fees will be paid to
the ERO within 24 hours of receipt of IRS funding.
If TPG does not receive an IRS refund on behalf of a taxpayer who selects a TPG product, no
fees – including the tax preparation fees charged by the ERO – will be paid. In the case of
such unfunded returns, the ERO must collect their fees directly from the taxpayer. The ERO
can check on the status of a taxpayer’s IRS refund using the TPG website. A small percentage
of refunds are funded one week past their expected funding date. If the refund is not
received more than one week past the expected IRS funding date, the ERO should contact
the taxpayer directly to collect the preparer fees.
2) Pay by ACH Direct Debit
The Fee Pay program is offered as part of the Fee Collect program. Fee Pay allows for the
taxpayers to pay tax preparation fees via ACH direct debit from their bank account.
Taxpayers must have a personal bank account to apply for Fee Pay. Fees are deducted
after the tax return is filed by the preparer and accepted by the IRS. If an ACH direct debit is
refused or rejected, the tax preparation fees are not paid and the taxpayer must make
arrangements to pay the fees directly to the tax preparer. The direct debit cannot be used to
pay amounts owed to the IRS. IRS or state tax payments must be made directly by the
taxpayer to the applicable tax authority.
2019 User Manual, 2019-1A, January 2019 13 of 363) Procedure for Offering a Fee Collect
Once the FC option is selected, the software will print out all the required documentation.
The taxpayer must sign all documentation, including the IRS 7216 Consent Forms before
the ERO transmits the tax return and the FC request. The documentation will consist of
the Tax Refund Deposit and Payment Authorization form, and the 7216 Use and
Disclosure Consent forms.
E) Taxpayer Advance
(Check with your software provider for availability. EROs cannot offer the Taxpayer Advance
unless specific due diligence criteria has been met. Not all EROs qualify.)
Taxpayer Advance is a tax refund advance program available to qualifying EROs and taxpayers. Not
all EROs are eligible to offer this program to taxpayers. If eligible, EROs can offer taxpayers a
Taxpayer Advance, which will be paid back upon IRS or state funding. If you participate in the
Taxpayer Advance, you can also choose to participate in TPG’s early taxpayer advance program,
which simply means you can offer taxpayers advances starting January 2, 2019. TPG has partnered
with a third party refund advance provider to offer this product for all EROs except those located
in Puerto Rico. The third party advance provider is not affiliated with TPG or Bank. Tax refund
advance proceeds are disbursed onto one of the most popular prepaid cards in the nation -- the
Walmart MoneyCard offered by Green Dot Bank or by cashier’s check.
Other key aspects of the Taxpayer Advance program include:
• The ERO is charged a different amount depending on whether the Taxpayer Advance is
funded before or after the IRS provides acknowledgement of receipt of the tax return. The
ERO is charged $79.00 for each funded pre-acknowledgement Taxpayer Advance and
$45.00 for each funded post-acknowledgment Taxpayer Advance. This fee is deducted from
ERO’s tax preparation fees. EROs are not charged for denied applications.
• EROs are prohibited from passing the taxpayer advance fee on to the taxpayers who
express an interest in obtaining a Taxpayer Advance. EROs may factor this expense in
generally as they consider tax preparation price increases applicable to all taxpayers as they
evaluate annual fee increases each year.
• The Taxpayer Advance loan amounts range from $500 to $6,000, giving the taxpayer the
best chance for approval of a Taxpayer Advance at an appropriate loan amount.
• The Taxpayer Advance program is designed to be affordable to the taxpayer. Taxpayers
may obtain 25% of the tax refund amount without paying any interest or loan fees for a
loan up to $2,000. Taxpayer Advance loan amounts greater than 25% of the tax refund
amount or $2,000, whichever is less, are charged a 36% APR on the total loan amount.
Taxpayers may therefore elect to apply for a Taxpayer Advance loan amount that has no
interest or fees, or a larger Taxpayer Advance loan amount that has a 36% APR.
• An RT is not required with Taxpayer Advance. That means a taxpayer can receive a
Taxpayer Advance and no RT and then must pay out of pocket for tax preparation fees.
There is an additional Tax Refund Deposit and Payment Authorization form which is used
for this purpose in lieu of the RT Application and Agreement. The Tax Refund Deposit and
Payment Authorization form contains a taxpayer authorization for a bank account to be
opened to receive the federal and if applicable, state tax refunds and to deduct the
Taxpayer Advance amount from the refund amount(s).
2019 User Manual, 2019-1A, January 2019 14 of 36• Separate 7216 Consents to Use and to Disclose for Taxpayer Advance must be used if the
taxpayer expresses an interest in obtaining a Taxpayer Advance. The standard 7216
Consents to Use and Disclose for RTs must also be used if an RT is offered.
• Taxpayer Advance proceeds and tax refund proceeds will be disbursed onto a Walmart
MoneyCard or cashier’s check. Under certain Programs, a specially-branded prepaid card
issued by Green Dot Bank may be used instead of the Walmart MoneyCard. EROs shall
incorporate tax preparer scripts regarding the Taxpayer Advance program that are
provided by TPG in their tax preparer training in connection with offering the Taxpayer
Advance program.
F) Taxpayer Identification
Under the TPG-required CIP procedures for TPG products, each taxpayer must be properly
identified. The ERO must inspect unexpired government-issued photo ID and SSN for each
taxpayer and confirm the identity and SSN of each dependent. Copies of the identification
should be retained unless prohibited by law. The ERO will also be required to obtain the mailing
address and physical residence address for each taxpayer as part of the electronic record.
Once the ID has been checked and the documentation is signed, the tax return and RT request
can be transmitted. TPG should receive the taxpayer’s IRS refund and TPG will transmit a
disbursement record to the ERO. If the taxpayer selected a check disbursement, the ERO will be
able to print a check at that time. If the disbursement is by direct deposit or prepaid card, the
funds will be available within 1 to 2 business days. If the taxpayer has an outstanding Taxpayer
Advance, the outstanding amount may be deducted from the refund before all fees have been
deducted and before any disbursement is made to the taxpayer.
DISBURSEMENT METHODS
If the taxpayer has a refund due on their tax return and the taxpayer has requested TPG to process their
refund, the taxpayer must choose the manner in which they want their refund proceeds disbursed. Once
a disbursement method has been selected, all subsequent disbursements will be made in the same
way. The following disbursement methods are available for RTs:
• Site Printed Cashier’s Checks
• ACH Direct Deposit to a checking account, savings account or filer owned prepaid debit card
• Walmart MoneyCard or other branded Green Dot Bank-issued prepaid debit card (if ERO qualifies)
• Walmart Direct2Cash
Depending on what software provider you use, Fee Collect disbursements may be limited. Check
with your software provider to determine what options your program provides.
If the disbursement option needs to be changed, the ERO is required to contact TPG so that the
request can be processed per policy.
A) Site Printed Cashier’s Check
Upon acceptance into TPG Program, EROs will be able to print TPG cashier’s checks directly from
their office. The check print program is integrated into the software program the ERO uses to
2019 User Manual, 2019-1A, January 2019 15 of 36prepare taxes. Authorization to print checks will be transmitted from TPG to the ERO through
the ERO’s transmitter. TPG will send a check print authorization to the transmitter after
receiving a tax refund from the IRS.
Each time the ERO connects to the transmitter, the transmitter will transmit all pending check
print authorizations to the ERO. Upon receipt of the check print authorization, the ERO should
be able to print checks. Any check printing problems should be directed to the
transmitter/software provider. The transmitter will provide all technical support for the check-
printing program. Most RTs will result in one or two check disbursements; however other
products such as a State Refund Transfer may generate additional check disbursements. Check
print disbursements may not all occur on the same day so the taxpayer may have to make
multiple trips to the ERO’s office to pick up all checks.
In certain cases (such as the printing of a third check) during and after the tax season, TPG may
print and mail checks directly to the taxpayer. Checks will be printed for the refund amount less
any fees withheld and are normally mailed using first class postage.
1) Description of the Check and Check Stub
Each check has an attached stub. The stub is initially blank (some software exceptions). Your
software will print the correct disclosure on the stub. Once printed, you are required to give
the taxpayer the check with the stub attached. In the case of an RT or overage check, an
itemization of the RT or overage will print. You should make a copy of the check with the
stub attached before handing the check to your customer and you should keep a copy of
the check and stub in client’s file.
Taxpayer Names Should Match Check Payee: It is extremely important to check the
taxpayer’s identification against the tax return file in order to ensure that the proper
check is handed out to the proper client. If the check is used to disburse proceeds to
taxpayers that filed jointly, both taxpayers’ names must appear as the payee on the payee
line. A check log is available for download from our website. Using this check log can help
you to avoid giving a check to the wrong customer. On the top portion of the reverse side
of the check there are two endorsement lines. There must be valid and legal endorsements
for all payees listed on the front of the RT check. On joint returns, both taxpayers must sign.
The only exceptions are where a taxpayer has died or where a Power of Attorney has been
presented. See the Check Exceptions section later in this manual for more detailed
information on endorsements.
ERO Liability for Check Errors: If you hand out a check to the wrong client and that check
clears and TPG is unable to get funds back on the check, you will be responsible to TPG
for the amount of the check (see the FSA).
2) Check Shipments
Check stock may be distributed directly from TPG, from the transmitter or from a Service
Bureau. The origin of the shipment is predetermined through contractual arrangement.
Please be extremely careful to verify check stock shipments against your packing slip and be
alert to any signs of tampering. Because delivery times are not always predictable, it is
strongly recommended that an accurate assessment of check stock be made prior to the
beginning of tax season.
2019 User Manual, 2019-1A, January 2019 16 of 36If checks are shipped direct from TPG, a packing slip will be included with each shipment.
It will identify: (a) the billing and shipping address, (b) the total number of checks shipped,
and (c) the check sequence number range of the shipment. A shipment receipt and
tracking number will be kept on file at TPG.
If checks are shipped from the transmitter or service bureau, checks are shipped to EROs
based on procedures established by the transmitter or service bureau.
3) Check Storage and Security
The check stock on which the taxpayers’ RT checks are printed are Bank cashier’s checks.
Cashier’s checks carry more credibility and authority than ordinary check stock. They also,
however, carry significantly more responsibility and require more care in handling. The
following outlines the minimum care required to maintain check stock:
• Checks must be stored in a secure area under lock and key, just as you would store
cash or personal checks. Access should be allowed to authorized personnel only. If
checks need to be transported from one location to another, the checks should not
be left in an unattended car.
• A check log will be maintained on a daily basis by the ERO. Entries will be required
each time that check stock is removed from storage and when a check is voided.
Comparisons between check sequence numbers printed, voided, and remaining stock
should be made, as unused checks are returned to storage. Every exception should be
documented. If a check is discovered to be missing, notify TPG customer support
immediately.
• Specific check sequence number ranges will be tracked for each site. For this
reason, transfer of check stock from one site to another, even if the sites are
affiliated with the same company, is prohibited unless authorized by TPG.
• Reorder requests must be completed through TPG’s website, www.sbtpg.com.
Check Stock Reconciliation:
An end of season reconciliation will be required, accounting for all checks issued, voided,
canceled, destroyed or remaining unused. Unused checks must be mailed back to TPG or
destroyed. If the check stock is destroyed, the ERO must fax TPG a completed Check Stock
Reconciliation Form.
This form can be downloaded from the TPG website. Misused or unaccounted for check
stock is the responsibility of the preparer and misuse is considered cause for termination
from the RT program.
4) Check Handling Exceptions
Lost or Stolen Check Stock:
What to do if the ERO loses blank check stock or blank check stock is stolen:
a. ERO should immediately call TPG and report the check numbers from the missing
check stock.
Voiding and Reissuing Checks:
What to do if checks are accidently damaged, torn, or used out of sequence by the ERO
‘prior’ to disbursement to the taxpayer:
2019 User Manual, 2019-1A, January 2019 17 of 36You can also read
