news.cuna.org/articles/107798-comments-on-third-party-senders-cuso-info-collection-due-in-oct

Comments on third-party senders, CUSO info collection due in Oct.

September 30, 2015

WASHINGTON (9/30/15)--Comments on third-party sender registration and credit union service organization (CUSO) information collection are due in October.

NACHA-The Electronic Payments Foundation, has proposed changes to its operating rules that would require originating depository financial institutions (ODFIs) to register third-party senders with NACHA. The resulting registry would standardize all data collected across all ODFIs, and provide information on third-party senders that would enable better monitoring by NACHA.

Third-party senders are defined as organizations that are not originators that authorized an ODFI to transmit a credit or debit entry, but acts like the ODFI to the originating institution.

ODFIs with third-party senders will incur some costs to assemble and report the information, third-party senders will likely incur some costs to assemble and provide information to their ODFIs and NACHA expects to incur costs to establish and maintain the registry.

Per the proposal, NACHA will recover its costs through a proposed registration charge to ODFIs for each registered third-party sender.

CUNA is seeking the following answers from ODFI credit unions:

  • Whether this proposal would affect credit union operations and third-party providers (e.g., corporate credit unions), and compliance on the ACH network?
     
  • Whether standardizing all of the basic data collected for all third-party senders would be burdensome to credit union?
     
  • How do credit union ODFIs collect information about third-party senders? And, does NACHA’s proposal appear to have the correct understanding of these efforts?
     
  • Do credit unions have the existing records about third-party senders that NACHA indicates they likely have in the proposal?
     
  • What are expected costs if this change is made? And, are these costs significant?

Comments are being accepted by NACHA through Oct. 9.

In addition, the National Credit Union Administration is seeking comments on revised information collection for the Office of Management and Budget.

Under the revisions, federally insured credit unions with an investment in, or loan to, a CUSO must obtain a written agreement with the CUSO addressing accounting, financial statements, audits, reporting and legal opinions.

All CUSOs are required to annually provide basic profile information to NCUA and the appropriate state supervisory authority. CUSOs engaging in certain complex or high-risk activities are also required to report more detailed information, including audited financial statements and customer information.

 Comments are due to the NCUA by Oct. 28.