The American Bankers Association on Tuesday offered feedback on a recent request by Nacha for comment on four risk management topics that could inform future actions by the organization, although no specific rules have been proposed. Specifically, Nacha was seeking input on the ACH network credit return threshold, third-party receivers, notification of change for standard entry class code/account type mismatch, and risk-based approach to early funds availability. In its comments, ABA recommended that the first three of the four topics be considered worthy as proposed rules. However, when it comes to rulemaking concerning early funds availability, “these are business decisions implemented by financial institutions and outside the scope of Nacha,” the association said.
“Recommendations to explore issues in greater detail should not be interpreted as endorsements of the proposal,” ABA said about its recommendations. “As these issues become more refined as formal rule proposals and final rules, the specific requirements of each change become very important in determining if the cost of implementing the change is worth the benefit gained. At this stage, those details are not known,” it added.