WASHINGTON (11/13/08)—Although recommending a few tweaks, the Credit Union National Association (CUNA) came out in support of a NACHA proposal to clarify its requirements for authorizations and returns. Specifically, NACHA is proposing to clarify the requirements for obtaining authorization of an automated clearinghouse (ACH) payment and amend its rules regarding the process by which receiving depository financial institutions (RDFIs) handle claims of unauthorized debits. Additionally, NACHA want to modify the ACH codes used to classify a return (return reason codes) to more effectively identify the reason an unauthorized debit is returned. In its Nov. 7 comment letter, CUNA said it supports NACHA’s proposal to clarify the requirements for obtaining a receiver’s authorization for an ACH payment by stating that an unclear, deceptive or otherwise invalid authorization is not valid. However, CUNA argued, the terms “unclear” and “deceptive” are subjective and should be clarified in the rules. CUNA also supported NACHA’s recommendation to eliminate all references to the phrase “penalty of perjury” with regard to a receiver’s written statement that a debit was unauthorized. Such a phrase may raise concerns that notarization may be required in certain jurisdictions, the CUNA letter warned. Use the resource link below to read the entirety of CUNA’s comments.