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Washington
CUNA to NACHA: Mind Compliance, Implementation Costs
WASHINGTON (4/8/13)--The Electronic Payments Association (NACHA) must minimize implementation and compliance costs as it works to clarify the meaning or intent of certain provisions, improve processing efficiency, and eliminate requirements that no longer add value to the ACH network, the Credit Union National Association said in a new comment letter.

The CUNA comment letter is in response to NACHA's latest compliance and operational topics proposal, which was released in February.

NACHA has proposed amending its operating rules by:

  • Removing change code C04 (incorrect individual name/receiving company name) to reduce compliance and liability challenges associated with name changes;
  • Reducing the mandatory six-day waiting period associated with prenotification (prenote) entries; and
  • Making technical corrections to the rules on the authorization of reclamation entries.
Originating depository financial institutions (ODFIs) and receiving depository financial institutions (RDFIs) would be impacted by these changes, CUNA Assistant General Counsel for Regulatory Research Dennis Tsang noted.

Tsang said CUNA generally supports the changes.

Reducing the mandatory six-day waiting period on prenotification entries, as proposed by NACHA, should help facilitate a more timely use of the prenote, and could also help reduce exceptions, Tsang wrote.

The proposed technical changes on authorization of reclamation entries would make the rules for reclamation entries consistent with the rules for reversing entries, he added.

For the full CUNA comment letter, use the resource link.
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CUNA Comment Letters
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