CUNA Regulatory Comment Call

November 24, 2008

NACHA Proposal On The Use Of Formatted Remittance Information For Certain ACH Payments

EXECUTIVE SUMMARY

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.coop and to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.coop; or mail them to Mary and Jeff c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may contact us at 800-356-9655, ext. 6732, if you would like a copy of the interim final rule. You may also access it here.

DISCUSSION OF PROPOSAL

QUESTIONS TO CONSIDER REGARDING THE SBA INTERIM FINAL RULE

  1. Do you support allowing XML-formatted payment-related information in ACH addenda records?

       Yes ________        No ________

    Please explain
















  2. Would you support sending XML-formatted payment information with SEC codes for which only one addenda record is permitted (CCD, CIE, PPD, and WEB)?

       Yes ________        No ________

    Please explain
















  3. NACHA’s proposal does not include the use of XML-formatted information for the DNE and ENR SEC codes because these are transactions limited to specific Federal government applications. Do you agree with this exclusion?

       Yes ________        No ________

    Please explain
















  4. NACHA’s proposal does not include the use of XML-formatted information for the TRX SEC code because because it is limited to check truncation transactions carrying National Association of Check Safekeeping syntax. Do you agree with this exclusion?

       Yes ________        No ________

    Please explain
















  5. The XML format takes significantly more space when building data files than the current SC X-12 formats. What do you believe would be the potential impact of processing significantly more addenda records to the Network?

       Yes ________        No ________

    Please explain
















  6. Do you believe there is a threshold above which the number of records becomes a detriment to ACH processing, and any potential costs associated with increasing the ability to handle a larger number of addenda records?

       Yes ________        No ________

    Please explain
















  7. Because XML-formatted information may be human-readable, it is possible that ACH addenda records carrying private information may be viewed by unintended third parties. Do you believe this would be problematic to credit unions?

       Yes ________        No ________

    Please explain
















  8. Do you support an implementation date of March 19, 2010?

       Yes ________        No ________

    If not, what date would be more appropriate?
















  9. Please provide any additional comments.
















    Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
    Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
    Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
    Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
    Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com