Electronic bill payment often worked directly from the consumer’s bank.7 The consumer established with his or her bank a file of merchants and regularly used either a telephone or PC to direct the bank to make payments to the merchants in the list. The bank transferred funds through the bill payment service CheckFree in 85 percent of transactions — and onto the Automated Clearing House System (ACH) whenever possible. Initially, these services ran via a touch-tone telephone or a direct dial up modem connection. The consumer was linked to the bank’s system using proprietary client software, some of which was provided by CheckFree. With the emergence of the Web, however, electronic payment services migrated there.