CUNA Comment Letter
Customer Service Telephone Number
July 31, 2006
Manager Network Rules
NACHA The Electronic Payments Association
13665 Dulles Technology Drive
Herndon, Virginia 20171
Dear Ms. Bondoc,
The Credit Union National Association (CUNA) is pleased to respond to NACHAs request for comment on its proposal to re-define the ACH record to accommodate a customer service telephone number (CSTN). This letter was prepared under the auspices of CUNAs Payment Systems Subcommittee, which is chaired by Ralph Jones, Executive Vice President of the Georgia Credit Union Affiliates, Georgia. By way of background, CUNA is the largest credit union trade association, representing approximately 90% of our nations nearly 8,900 state and federal credit unions, which serve nearly 87 million members.
Summary of CUNAs Position
- CUNA supports NACHAs proposal to re-define the ACH record to accommodate a customer service telephone number (CSTN).
- CUNA believes using an originators telephone number rather than an agencys telephone number or third party service providers number would better serve RDFIs managing risk.
- CUNA believes the second phase of NACHAs proposal to include the originators CSTN in the RDFIs periodic statement would be beneficial to credit union members, but encourages NACHA to make the inclusion of the telephone number on the receivers periodic statements optional.
- CUNA suggests implementation dates of March 21, 2008 for Phase One and September 21, 2008 for Phase Two.
Discussion of CUNAs Views
We support NACHAs proposal to re-define the ACH record to accommodate a customer service telephone number (CSTN). NACHA is proposing a two-phased implementation process. The initial phase would require originators to include their CSTN in the Company/Batch Header Record for all Standard Entry Class (SEC) Codes except cross-border entries. We fully support the inclusion of a CSTN in the Company/Batch Header Record. This would benefit receivers and reduce customer service burdens on Receiving Depository Financial Institutions (RDFIs). Currently, RDFI staff must research the Originating Depository Financial Institutions (ODFIs) routing and transit number to find the ODFI telephone number. Including the CSTN on the ACH Company/Batch Header would give staff easier access to the numbers and would enable staff to more effectively respond to member/receivers inquiries regarding ACH transactions that have posted to their account.
Additionally, providing a CSTN can be used in a risk management capacity. We believe using an originators telephone number rather than a third partys number would better serve RDFIs in this capacity. A telephone number that is unique to originator will enable RDFIs to track an originators transactions for risk management purposes. It would also help receivers contact an originator directly about a transaction rather than an agent or third-party service provider.
We believe the second phase of NACHAs proposal to include the originators CSTN in the RDFIs periodic statement would be beneficial to credit union members because it would enable them to contact the originator directly rather than go through the RDFI for questions about their transactions.
Credit unions have experienced instances in which originators would not disclose transactional information to their staff. This requires credit union staff to give the telephone information to their members/receivers so that they could communicate directly with the originator. Adding the originators CSTN to the periodic statements would eliminate the additional step for members/receivers and RDFIs.
Additionally, telephone numbers that are parsed with dashes would helpful to consumers as they would recognize the number as a telephone number on their periodic statements. However, we do not believe that this should be mandatory. RDFIs would need to program their system to print and display the appropriate fields so that the telephone numbers are displayed on the periodic statements. We encourage NACHA to make the inclusion of the telephone number on the receiver statements optional.
NACHA is proposing implementation dates of September 21, 2007 for Phase One and March 21, 2008 for Phase Two. We believe additional time is needed and suggest implementation dates of March 21, 2008 for Phase One and September 21, 2008 for Phase Two. These dates are more appropriate because it will allow time for financial institutions to work with Origination software vendors to develop, test and implement the changes. Additionally, it will provide time to educate members and staff about the new requirements as well as give Originators time to obtain a working customer service telephone number.
CUNA supports NACHAs proposal to include a customer service telephone number in the ACH Company/Batch Header. It would benefit both the RDFIs and receivers when there are questions about an ACH transaction. If you have any questions, please contact me at (202) 638-5777.