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CUNA Seeks Comment On Two ACH Proposals
WASHINGTON (11/19/13)--Credit unions have until Jan. 13 to comment on a pair of NACHA--The Electronic Payments Association proposals that aim to reduce risk and exceptions on Automated Clearing House (ACH) networks. 
 
The Credit Union National Association is interested in how these proposals would affect credit union operations and compliance on the ACH Network and will develop a comment letter to NACHA. CUNA seeks credit union comment by Dec. 16 to help inform the CUNA letter.
 
The first of the two NACHA proposals addresses ACH Risk and Enforcement. The proposal would improve NACHA's ability to identify and enforce rules against "outlier" originators responsible for the highest levels of exceptions. The proposal would also:
  • Reduce the existing return rate threshold for unauthorized debits from 1.0% to 0.5%;
  • Establish a return rate threshold for account data quality returns (i.e., administrative returns) at 3% and an overall debit return rate threshold (for all return reason codes) at 15%;
  • Clarify the definition of a "reinitiated entry";
  • Apply risk management rules to third-party senders; and
  • Expand NACHA's enforcement authority.
The second proposal aims to reduce exceptions by establishing economic incentives for Originating Depository Financial Institutions (ODFI) to improve the quality of ACH transactions they originate. Under the proposal, an ODFI would pay fees based on exceptions to partially offset the Receiving Depository Financial Institution's costs for exception processing and customer service. This would happen in the following instances:
  • A return due to erroneous data;
  • A notification of change; and/or
  • A return due to an unauthorized entry.
To comment on the NACHA proposals, use the resource link.
Other Resources

CUNA Comment Call
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