WASHINGTON (1/22/15)--Regulatory staff at the Credit Union National Association is seeking input on the proposed same-day automated clearinghouse (ACH) transactions rule, particularly from smaller credit unions. The proposal has been put forth by NACHA--The Electronic Payments Association.
The rule would amend the NACHA operating rules to enable an option for same-day processing of virtually any ACH payment. The exceptions would be international transactions and individual transactions of more than $25,000.
All receiving depository financial institutions (RDFIs), including credit unions, would be required to receive same-day ACH payments in order to provide certainty to originators desiring same-day transactions. All RDFIs will incur implementation and ongoing operating costs if the proposal is adopted in its current form.
Since nearly all credit unions would be subject to the new rule, regardless of size, CUNA's regulatory advocacy staff seeks input from credit unions on how the rule would affect their operations.
"CUNA appreciates the comments we have received thus far, most of which have been from larger credit unions," said Luke Martone, CUNA's senior assistant general counsel for regulatory affairs. "However, in order to ensure our comment letter accurately represents our membership, we are still pursuing input from smaller credit unions, those with less than $50 million in assets, and credit unions with limited operating hours and staff. Those credit unions could be most affected by the proposal."
The main questions CUNA seeks input on are:
Once those questions are answered, CUNA staff is interested in details, such as the estimated costs of compliance, as well as credit unions' thoughts on what changes will need to be made in order to comply with the rule.
NACHA has proposed a phased implementation approach, starting in September 2016. Comments are due to CUNA by Jan. 23, and comments are due to NACHA by Feb. 6.