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CUNA Regulatory Comment Call

February 25, 2000

EXECUTIVE SUMMARY

• NACHA requests comments on a survey that assesses the quality of the automated clearing house (ACH) network. Send a copy to NACHA and CUNA at dbarr@nacha.org and mprofit@cuna.com.
• NACHA must receive comments by March 15, 2000. Please submit your comments to CUNA by March 8, 2000 by fax at 202/371-8240 or by e-mail to CUNA's Assistant General Counsel Michelle Profit at mprofit@cuna.com.
• CUNA will use responses to the survey and the questions below to develop a concept paper on the ACH network. CUNA will also use this information to write comments to NACHA.

In addition to this survey, please answer the following questions below that are geared toward credit unions:

QUESTIONS

• Has your credit union seen the same ACH items being presented against a member's account multiple times, incurring multiple fees for insufficient funds? If so, was this ACH item generated by a point-of-sale conversion or a represented- check-item or another ACH transaction?




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• Would it be helpful to limit all ACH presentments to three times?




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• Have share drafts that have had a stop payment placed on them been cleared as ACH items? Please describe how this happened and whether this presents a problem for your credit union.




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• Do you know of or use any software that would prevent a share draft with a stop payment order on it from being cleared as an ACH item? Please describe this software. If you manually process ACH items and share drafts, are there any procedures or systems you use to prevent circumvention of stop payments? Please explain.




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• Please describe any ACH rule changes that may help solve the problem caused by share drafts that are cleared as ACH items, when a stop payment was placed on the original check.




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• Have you noticed any merchant practices that may reduce the quality of the ACH network? If so, please describe. Are there any changes to the ACH rules that would address these problems?




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• Has your credit union suffered a loss because of ACH items that the member refused to pay or the originating institution would not recredit? Please describe the situation and whether you believe that it warrants changes in the ACH system? If changes are necessary, what are they?




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• Have you encountered any problems with returning ACH items? Please describe. If this is an issue for you, does it warrant changes to the ACH rules? If so, what kind?




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• Please describe any other problems or positive characteristics you see in the ACH system.




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• Are there any other ACH rules that you would like to see change?




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• How can CUNA help improve the ACH network and assist credit unions that use the network?




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