WASHINGTON (10/13/15)--Though the proposal will likely affect only a small number of credit unions, CUNA has asked for clarifications on NACHA-The Electronic Payments Association’s proposal regarding registration of third-party senders.
CUNA commented on two aspects of the proposal--standardizing data and the registration charge for originating depository financial institutions (ODFIs).
The proposal would require ODFIs to register third-party senders with NACHA. Third-party senders are defined as organizations that are not originators that authorized an ODFI to transmit a credit or debit entry, but act like the ODFI to the originating institution.
According to the proposal, the ODFI must pay NACHA a registration charge established by NACHA “from time to time” for each third-party sender required to be registered.
“We believe the vagueness of ‘from time to time’ must be clarified because costs could greatly vary depending on what NACHA means by this,” CUNA’s letter reads. “In NACHA’s survey it appears that the charge is between $100 and $1,000, which could be significant if required frequently. It is important for ODFIs to understand how 'from time to time' will be interpreted so that they can plan and budget accordingly.”
CUNA agrees with the proposal’s intent to standardize across all ODFIs the basic data collected for all third-party senders, since it believes this standardization would be beneficial for credit unions using third-party senders.
“Having an unstandardized data collection effort that varies from ODFI to ODFI could be problematic for credit unions if participants are not all collecting the same information,” the letter reads. “To assure consistency throughout the market, we believe it is a good idea to require this.”