CUNA Regulatory Comment Call


June 9, 2003

Operational Efficiency for ACH
(A MINOR RULE)

EXECUTIVE SUMMARY

NACHA-The Electronic Payments Association has issued a request for comments on a proposal that would change minor, technical rules. Comments on the proposal are due to NACHA by June 27, 2003 and to CUNA by June 19. The request for comment proposes to modify the NACHA Operating Rules in the following ways:

Please send your comments to CUNA by June 19, 2003. Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com and Assistant General Counsel Michelle Profit at mprofit@cuna.com; or mail them to Mary and Michelle c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, D.C. 20004.

In addition, CUNA recommends that all credit unions respond directly to NACHA because NACHA tabulates results to its surveys. If you would like to respond directly to NACHA and copy CUNA you may do so by using the NACHA survey form at http://www.nacha.org/ACH_Rules/Rule_Making__Process/Rules_Work_Groups/RFC-52/rfc_52.htm. Comments sent directly to NACHA should be sent to Maribel Bondoc, Network Services Assistant, NACHA, 13665 Dulles Technology Drive, Suite 300, Herndon, VA 20171, fax: (703) 787-0996 or email: mbondoc@nacha.org, no later than Friday, June 27, 2003. Please provide CUNA a copy by sending your comments to Mary Dunn at mdunn@cuna.com Michelle Profit at mprofit@cuna.com.

QUESTIONS REGARDING THE PROPOSAL

  1. Does your credit union support the modification of the return code R12 from "Branch Sold to Another DFI" to "Account Sold to Another DFI"?













  2. Does your credit union support the clarification of the description of excused delay, so that it is clear that delays are excused only for catastrophes and not for normal processing problems?













  3. Does your credit unions support the requirement that RDFIs audit themselves to ensure that they include the check serial number for Destroyed Check Entries (XCK) on these items and member statements?













  4. Do you support the ACH Operator request to expand certain credit and debit fields for the Automated Account Advise standards entry class code?













    Please submit your name, address, and phone number.













Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com