WASHINGTON — In a comment letter to NACHA–the Electronic Payments Association–CUNA encouraged the standard setting entity to reconsider many of the provisions in its proposal on Network Enforcement Rules.

“Currently, NACHA cannot compel Originating Depository Financial Institutions (ODFIs) to stop originating ACH transactions for the highest risk users, such as customers with excessive returns,” CUNA Assistant General Counsel Lilly Thomas wrote. “Expanding the enforcement procedures will help achieve NACHA’s goals of ensuring high-quality ACH transactions and reducing risk while not burdening all ACH participants.”

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