WASHINGTON (8/22/11)—The Credit Union National Association (CUNA) is concerned by potential increases in ACH system compliance and implementation costs, and has offered several recommendations on how NACHA, the electronic payments association, can improve the network. NACHA has proposed several changes to its operating rules that would eliminate some so-called "pain points," areas of misunderstanding, and other problems that it identified during a rules simplification initiative that it completed earlier this year. Among those changes are requiring written authorization for debit entries to a business account if there is no existing contract or relationship. The association is also considering providing a new return reason code to stop all future payments and removing the current requirement of separate Web Initiated-Entry exposure limits for originating depository financial institutions (ODFIs). NACHA may also remove a current requirement which states that an ODFI must suffer a loss to dishonor an untimely return. For CUNA’s comment on these issues, use the resource link.