WASHINGTON-CUNA wrote the Federal Reserve Board in response to a request for comment that its proposed survey of institutions on Check 21 gets too much into the nitty-gritty. CUNA applauded the Fed’s initiative to obtain feedback on Check 21 but feels the specific data the Fed is requesting would be burdensome for credit unions and others to collect. “We believe that while the information that the Board is seeking in its survey is available at institutions, it may not be easily accessible,” CUNA wrote. “Retrieving requested information might be challenging for those institutions that do not specifically store certain information in a format that is readily available.” For example, check losses and returns specific to local or nonlocal checks or presentment methods are not usually stored for easy retrieval. CUNA asked that the Fed request information that does not seek specific statistical data. If the questions remain as they are, the trade association requested that those institutions surveyed be notified well in advance to give them time to prepare. CUNA’s comment letter also stated that a narrative section would be helpful on the survey. Additionally, CUNA suggested, that the Fed hold off on changes to the maximum hold period under Regulation CC until the full impact of Check 21 on the check processing system can be assessed.

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