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Removing Barriers Blog

Letter to NACHA on Registration of Third Party Senders
Posted October 09, 2015 by CUNA Advocacy

Today we sent a comment letter in response to NACHA – The Electronic Payments Association requests for comments on proposed changes that would require Originating Depository Financial Institutions (ODFIs) to register their Third-Party Senders with NACHA.

We don’t anticipate this proposal to have a major impact on credit unions, but we wanted to weigh in on a couple of specific points in the event that it impacts any credit unions. An ODFI without a Third Party Sender would not be required to submit any additional information to NACHA. However, there may be some credit unions that have a relationship with Third-Party Senders, and are impacted by the proposal.

Our comment addressed two issues:

Standardizing Data

In its proposal, NACHA states that it plans to standardize across all ODFIs the basic data collected for all Third-Party Senders. Our letter noted that we believe that standardizing the basic data would be beneficial for credit unions using a Third Party Sender because having an unstandardized data collection effort that varies from ODFI to ODFI could be problematic for credit unions if participants are not all collecting the same information.

Costs to ODFIs

The proposal states that the ODFI must pay NACHA a registration charge that is established by NACHA from time to time for each Third-Party Sender required to be registered. We stated that we believe the vagueness of “from time to time” must be clarified because costs could greatly vary depending on what NACHA means by this. In NACHA’s survey it appears that the charge is between $100 and $1000, which could be significant if required frequently. It is important for ODFIs to understand how “from time to time” will be interpreted so that they can plan and budget accordingly. WE’s comment suggested that NACHA provide more clarity about its proposed registration charge.

As NACHA continues to make changes to move towards a faster payments system, we will continue to monitor these changes and weigh in with any credit union concerns.