CUNA Comment Letter

Customer Service Telephone Number

July 31, 2006

Maribel Bondoc
Manager Network Rules
NACHA – The Electronic Payments Association
13665 Dulles Technology Drive
Suite 300
Herndon, Virginia 20171

Dear Ms. Bondoc,

The Credit Union National Association (CUNA) is pleased to respond to NACHA’s 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 CUNA’s 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 nation’s nearly 8,900 state and federal credit unions, which serve nearly 87 million members.

Summary of CUNA’s Position

Discussion of CUNA’s Views

We support NACHA’s 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 Institution’s (ODFI’s) 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 originator’s telephone number rather than a third party’s number would better serve RDFI’s in this capacity. A telephone number that is unique to originator will enable RDFIs to track an originator’s 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 NACHA’s proposal – to include the originator’s CSTN in the RDFI’s 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 originator’s 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.

Conclusion

CUNA supports NACHA’s 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.

Sincerely,

Lilly Thomas