In a letter to NACHA last week, ABA offered support for several proposed changes aimed at improving and simplifying the ACH user experience while maintaining system efficiency. NACHA issued the proposal as part of an ongoing effort to streamline the ACH operating rules to reduce the overall compliance and administrative burdens. ABA supported five separate proposals that would:
- Define and enable the use of “standing authorizations” for consumer debits
- Define and allow the use of oral authorizations of consumer ACH debits beyond telephone calls
- Clarify authorization standards for consumer ACH debits across payment authorization and initiation channels
- Reduce the administrative burden of providing proof of authorization of a consumer debit
- Reduce the burden associated with the written statement of unauthorized debit by facilitating the use of electronic and oral statements.
ABA also responded to a request for information on the creation of a dispute mechanism to resolve authorization disputes between ACH originators and receiving depository financial institutions. ABA noted that due to a lack of data, “it is difficult to determine if the benefits of setting up and maintaining a new, and possibly expensive, dispute resolution framework within the ACH network is preferred over the current requirement that these cases be pursued outside of the ACH network.” The association urged NACHA to provide further details on the number of repudiated transactions and the range of dollar amounts involved for the most recent three-year period possible.
