HERNDON, Va. — CUNA and NAFCU both expressed support for NACHA's attempt to redefine the ACH record to accommodate a customer service telephone number, but provided different changes they would like to see made.

Both groups supported including a customer service telephone number for the originator in the automated clearinghouse record, but diverged on how it should be accomplished. CUNA suggested that it be included in the Company/Batch Header Record as NACHA–the Electronic Payments Association–proposed while NAFCU recommended it be placed in the Company Entry Description Field.

"One potential drawback to the use of the Company Entry Description Field for the CSTN is that financial institutions may be using it to comply with Regulation E and its requirement that the account holder statement identify the type of transfer involved in the transaction," NAFCU President and CEO Fred Becker wrote. "However, NAFCU believes that the CSTN could serve as an adequate descriptor; and it is an information-rich resource in that it is a direct conduit to Originator–the initiator of the transaction." On the positive side, it would not require any programming changes, it is already required to be printed on statements and implementation could be nearly immediate.