WASHINGTON (9/26/12)--The Credit Union National Association (CUNA) in a comment letter said it supports the Electronic Payments Association's (NACHA) technical changes that would improve elements of the automated clearinghouse network, but also asked NACHA to limit additional implementation and compliance costs as it finalizes its proposal.
The NACHA changes would clarify the meaning or intent of some provisions, improve payment processing efficiency, and eliminate requirements that no longer add value to the ACH network.
One portion of NACHA's proposal would allow financial institutions that receive business debit entries to request proof of authorization from originating institutions, and would require those originators to provide that proof within 10 business days. CUNA suggested that NACHA could further clarify these changes by stating that the authorization requirement would only apply in the event of a dispute, or when charge receivers and originators do not have a pervious relationship. "The proposed requirement should not affect specified requirements under an existing contract or relationship between a business Receiver and Originator," CUNA Regulatory Counsel Dennis Tsang wrote.
The comment letter also suggested that NACHA minimize compliance burdens and permit the proof of authorization to be provided in whatever form is available instead of a specific data format.
Changes to stop payment processes and how erroneous transactions are handled are also addressed in the comment letter.
For the full comment letter, use the resource link.