WASHINGTON (6/26/13)--The Credit Union National Association generally supports clarifications proposed by NACHA--The Electronic Payments Association regarding operational issues relating to third parties in the Automated Clearing House (ACH) network, and encouraged NACHA to do even more to clarify its operating rules in ways that minimize compliance burdens on credit unions and other financial institutions that must follow NACHA standards.
NACHA's changes, proposed May 20, would clarify the definitions, roles, and responsibilities of service providers and senders that are third parties, and are intended to strengthen NACHA operating rules compliance among ACH participants. The proposal addresses five areas:
Clear identification of the originator in consumer debit authorizations;
Third-parties and receiver authorizations;
Definition of "third-party sender;"
Definition of "third-party service provider;" and,
Third-party audit requirements.
CUNA Assistant General Counsel Dennis Tsang wrote that the NACHA clarification sand technical changes should be helpful for third-parties as well as for other entities in the ACH network, including credit unions that use such entities for processing.
He said CUNA backs NACHA's plan to provide supplemental information in the operating guidelines, which should provide examples regarding the new rules. CUNA also encouraged the development of additional resources that would be directed to smaller financial institutions for compliance and implementation purposes, and offered to collaborate on that effort.
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