WASHINGTON—NAFCU has made a number of recommendations to the National Automated Clearinghouse Association (Nacha) in response to its request for information (RFI) on automated clearinghouse (ACH) risk management and Nacha operating rules.
In NAFCU’s letter, Senior Regulatory Affairs Counsel James Akin said the trade group, supports establishing a rate of return threshold for ACH credits, but that monitoring and addressing excessive administrative returns of ACH credits would allow the industry to “proactively identify potential fraud scenarios and take necessary preventive measures.”
In addition, Akin noted support for the proposal to acknowledge and define third-party receivers and have them comply to the same rules depository financial institutions follow.
‘Tentative’ Support
Moreover, Akin wrote that NAFCU “tentatively supports” the proposed inclusion of a new notification of change for SEC Code/Account Type mismatches but urged Nacha to conduct a cost-benefit analysis before issuing a proposed rule. One OneHowever, Akin voiced NAFCU’s opposition to the proposed risk-based approach to early funds availability, highlighting that the risk level associated with early funds availability should be determined by individual financial institutions.
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