WASHINGTON — America’s Credit Unions is urging Nacha to slow down proposed changes to ACH processing rules, warning that accelerated return deadlines and revised “Banking Day” requirements could impose disproportionate operational burdens on smaller credit unions.
In three comment letters submitted to Nacha, the trade group said it supports efforts to improve the speed and efficiency of the ACH network but argued additional research and industry outreach are needed before implementing changes that would require faster processing or expand institutions’ obligations.
Among its recommendations, America’s Credit Unions said:
- Nacha should gather additional data before shortening return and dispute timeframes.
- Smaller receiving depository financial institutions (RDFIs), including many credit unions, often rely on manual ACH processing and have limited staffing.
- Any changes should avoid shifting greater operational and compliance burdens onto community financial institutions.
- Credit unions should retain flexibility to voluntarily adopt faster processing if their staffing and technology support it.
Letter on Shortened Deadlines
In one letter, America’s Credit Unions cautioned against shortening deadlines for contesting or correcting dishonored ACH returns. The organization said many disputes involve unauthorized transactions governed by the Electronic Fund Transfer Act’s 60-day consumer protections, making rapid investigations difficult. It urged Nacha to publish more data identifying the primary causes and return codes associated with dishonored returns before proposing rule changes.
Letter on Expedited Return Timeframes
In a second letter, the organization addressed Nacha’s proposal to establish expedited return timeframes for routine transactions, such as closed accounts and duplicate payments. America’s Credit Unions said faster returns could improve network efficiency but warned the proposal would require many credit unions to invest in additional automation, system modifications, staff training and monitoring. The group also questioned whether the benefits to the ACH network would justify those costs for smaller institutions.
Letter on Definition of ‘Banking Day’
The third letter focused on Nacha’s review of the definition of “Banking Day.” America’s Credit Unions said credit unions vary widely in their operating hours, with many maintaining member services during weekends while not staffing back-office ACH operations. The organization urged Nacha not to adopt rules that would effectively require institutions to process ACH exceptions, returns or documentation requests on days when they are closed. It also called for greater alignment among Nacha, the Federal Reserve and The Clearing House definitions of “Banking Day” to reduce confusion and compliance risks, provided any changes account for the operational realities facing smaller institutions.
Throughout the letters, America’s Credit Unions said it supports modernization of the ACH network but maintained that any rule changes should preserve operational flexibility, avoid creating unintended compliance risks for smaller institutions, and be accompanied by sufficient implementation time and supporting data.
