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MCUA Comments on NACHA's Latest Compliance & Operational Topics Proposal

The Missouri Credit Union Association (MCUA) has filed a comment letter on The Electronic Payments Association's (NACHA) latest compliance and operational topics proposal. MCUA generally supports these changes to clarify the meaning or intent of provisions, improve processing efficiency, and eliminate requirements that no longer add value to the ACH network.  While these are mostly technical changes, MCUA asked NACHA to minimize implementation and compliance costs on Originating Depository Financial Institutions (ODFIs) and Receiving Depository Financial Institutions (RDFIs) affected by these changes. Specifically, this proposal would amend the NACHA Operating Rules 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, and
  3. Making technical corrections to the rules on the authorization of reclamation entries.


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