* Step 1: Transfer funds from each Employer's account to Cachet's holding account
* Step 2: Transfer funds from Cachet's holding account to each Employee account
Both of these steps are handled with an 'instructions file'.
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The crime (or horrible mistake that really looks like a crime):
Step 1's file was changed so that the funds went to an account at Pioneer Savings Bank (controlled by MyPayrollHR)
Step 2's file was sent as it normally would be.
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Mistake 1: The file for Step 2 was processed, and funds from Cachet's holding account were transferred to employees, despite funds from Employers not coming in.
Apparently Cachet had at least $26M extra in their holding account for this to work.
As a result of this, Cachet tried to reverse these transactions, since basically they hadn't actually been paid.
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Mistake 2: The reversal file was improperly formatted. NACHA rules say these files should be ignored or rejected, but..
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Mistake 3: Some financial institutions processed the improperly formatted file anyway.
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To fix Mistake 2, Cachet submitted a new reversal file, which was then also processed by the companies.
It sounds like this "reversal file" was actually just a transfer in the other direction (as opposed to "undo transaction ID 937641745"), so of course it would make sense that it was processed.
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As a result, all employees paid via MyPayrollHR were paid, then had that payment removed. Some also had the same payroll amount removed a second time.
One thing I haven't figured out, is apparently the MyPayrollHR account at Pioneer Savings Bank is 'frozen' -- but I can't find any reporting about whether it has $26M in it or not. Meanwhile the CEO has disappeared.. So did he get the money, or just cause a massive life disruption for thousands of people?