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Focus on NACHA and ACH Rules

The Missouri Credit Union Association (MCUA) sent a comment letter on October 9, 2015, to NACHA - the Electronic Payments Association regarding their request for comments on proposed changes that would require Originating Depository Financial Institutions (ODFIs) to register their Third-Party Senders with NACHA. 

MCUA believes the proposed changes concerning registration will likely only affect a small portion of corporate credit unions because an ODFI with no third-party sender would not be required to submit any information to NACHA. However, there may be some credit unions that have a relationship with Third-Party Senders, and are impacted by the proposal.

In its proposal, NACHA states that it plans to standardize across all ODFIs the basic data collected for all Third-Party Senders. Having an unstandardized data collection effort that varies from ODFI to ODFI could be problematic for credit unions if participants are not all collecting the same information. To assure consistency throughout the market, MCUA believes it is a good idea to require this.

The proposal states that the ODFI must pay to NACHA a registration charge that is established by NACHA from time to time for each Third-Party Sender required to be registered. MCUA believes the vagueness of “from time to time” must be clarified because costs could greatly vary depending on what NACHA means by this. In NACHA’s survey it appears that the charge is between $100 and $1,000. It is important for ODFIs to understand how “from time to time” will be interpreted so that they can plan and budget accordingly.