CUNA Regulatory Comment Call


July 29, 2003

ACH Returns
ACH Operator Requirements

EXECUTIVE SUMMARY

BACKGROUND

ACH Operator Edit Criteria

Settlement of Return Entries

DESCRIPTION OF THE PROPOSAL

QUESTIONS REGARDING THE PROPOSAL

  1. Does your credit union agree with the modification of the eleventh bullet of Return Reason Code R26 (Mandatory Field Error) to remove the ACH Operator mandatory field error edit on the Original RDFI Routing Number Field within dishonored returns and contested dishonored returns as this field is not defined as a mandatory field?

    Yes ______ No ______

    Please explain why or why not.
















  2. Does your credit union agree with the proposal related to the ACH Operators' modification to prohibit the settlement of returns prior to the effective entry date of the original entry?

    Yes ______ No ______

    Please explain why or why not.
















  3. Is your credit union able to return entries prior to the effective entry date of the original entry?

    Yes ______ No ______

    If yes, will the Rules modification cause your credit union to make any changes to your return practices?
















  4. Please describe any specific benefits or disadvantages to your credit union that would result from the proposed Rules changes.
















  5. Would this proposed change require your organization to make changes to its ACH software?

    Yes ______ No ______

    If yes, how extensive would the required software change be (very extensive, moderately extensive, somewhat extensive, minimally extensive)?

    Please explain.
















  6. How costly would the change be (highly costly, moderately costly, somewhat costly, minimally costly)?

    Please explain.
















  7. Does your credit union agree that the recommended implementation date of March 12, 2004 is an adequate time frame for implementing the proposed Rules changes?

    Yes ______ No ______

    If no, what time frame would be adequate?
















  8. Other comments?
















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