NACHA Proposal on Compliance & Operational Topics
NACHA - The Electronic Payments Association has issued another proposal to address certain compliance and operational topics on the Automated Clearing House (ACH) network. Specifically, this proposal would amend the NACHA Operating Rules on three topic areas by: 1) removing change code C04 (incorrect individual name/receiving company name) to reduce compliance and liability challenges associated with name changes, 2) reducing the mandatory six-day waiting period associated with prenotification (prenote) entries to permit live entries by an Originator to a Receiver’s account if a return of the prenote has not been received by the Originating Depository Financial Institution by the opening of the second banking day following the prenote settlement date, and 3) making technical corrections to the rules on the authorization of reclamation entries. NACHA believes these technical amendments would clarify meaning or intent, improve processing efficiency, and eliminate requirements that no longer add value to the ACH network. The Credit Union National Association (CUNA) is interested in how this proposal would affect credit union operations and compliance on the ACH network. Please review the CUNA Comment Call on this proposal and submit your comments to CUNA by March 25, 2013.