CUNA and NAFCU have weighed in with generally approving comments on recent proposed changes to the Automated Clearing House operations and procedures by NACHA – The Electronic Payments Association.
NACHA administers the ACH system which process electronic payments.
NACHA requested comments on changes it proposed to make on pre-notification entries to ACH transactions, its proposal to eliminate the Notice of Change 'Change Code 04′ and to make changes on rules overseeing reclamation entries.
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"NAFCU supports the proposed rule," the association said in its April 4 letter. "The proposed changes on pre-notification entries, by reducing the waiting period from six banking days to the day the entries' return period expires, will help expedite processing while also simplifying the process. At the same time, it will provide all parties in the transaction with adequate time to make necessary changes and issue appropriate notification."
NAFCU also expressed support for the elimination of Change Code 04 and other technical changes. "These proposed changes will make the rules easier to understand and follow, and enable improved levels of compliance," NAFCU added.
CUNA offered its own detailed comment to the proposals.
"We generally support the proposed authorization requirement for business debit entries that would permit the Receiving Depository Financial Institution (RDFI) to request proof of authorization and require the Originating Depository Financial Institution (ODFI) to provide proof of authorization within 10 business days," CUNA wrote in its letter this week to NACHA.
"However, NACHA should clarify that the requirement should only be used to facilitate the resolution of disputes and suspected entries that may be unauthorized or fraudulent between a business Receiver and RDFI in the limited circumstance in which the business Receiver and Originator do not have an existing contract or relationship…. NACHA should also minimize compliance burdens and permit the proof of authorization in whatever form is available instead of a specific data format," CUNA added.
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