WASHINGTON-Two national credit union trade associations in the Washington, D.C.-area have submitted comments to NACHA (the Electronic Payments Association) regarding its re-presented check proposal. Generally, CUNA does not support the proposal because of the extensive costs, re-training, new programming and an expected “deluge” of consumer questions. According to CUNA as many as 19 million inquiries could be fielded given the 4.8 million service fees assessed last quarter. NAFCU, on the other hand, was generally supportive of the idea. NAFCU wrote that it agrees with the “notice equals authorization” and even stated that a second notice to the consumer would not be practical, because the cost of storing all customers’ contact information, whether they bounce a check or not, would negate any savings from performing the transaction electronically. If the proposal is approved, both groups agreed that the underlying debt should be collected before the service fee. Both also said that unique codes should be used for the ACH entries to aid tracking by the recipient. In addition, CUNA suggested inclusion of the check number and the merchant’s phone number on the ACH. The proposed implementation date is March 14, regarding which NAFCU requested more time for training and reprogramming. NAFCU suggested September 2003 or later.

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