April 4, 2013
Maribel Bondoc
Manager, Network Rules
NACHA- The Electronic Payments Association
13450 Sunrise Valley Drive, Suite 100
Herndon, Virginia 20171
RE: Request for Comments – Compliance and Operational Topics
Dear Ms. Bondoc:
On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I write to you regarding the request for comments issued by NACHA–the Electronic Payments Association (NACHA) regarding various compliance and operational topics. The request for comments addresses potential changes in the NACHA Operating Rules on (1) prenotification entries; (2) elimination of Notice of Change “Change Code 04”; and (3) technical changes on rules governing reclamation entries to make them consistent with rules on reversing entries.
NAFCU supports the proposed rule. First, the proposed changes on prenotification entries, by reducing the waiting period from six banking days to the day the entries’ return period expires, will help expedite processing while also simplifying the process. At the same time, it will provide all parties in the transaction with adequate time to make necessary changes and issue appropriate notification.
We are also supportive of the proposed elimination of Notification of Change (Change Code 04) and the technical changes on the rules on reclamation entries. These proposed changes will make the Rules easier to understand and follow, and enable improved levels of compliance.
NAFCU appreciates the opportunity to comment. Should you have any questions or require additional information please feel free to contact me at ttefferi@nafcu.org or (703) 842-2268.
Sincerely,
Tessema Tefferi
Senior Regulatory Affairs Counsel