Executive Summary

•  NACHA – The Electronic Payments Association’s has issued a Request for Information (RFI) to seek information on the possible expansion of the number and types of addenda records available for use with automated clearing house (ACH) payments.

•  Based on feedback received, NACHA may develop specific proposals to amend the NACHA Rules.

•  NACHA is primarily interested in four topic areas:

     1) Expanding the allowed number of addenda records to nine for all Standard Entry Class (SEC) Codes that currently are limited to zero or one addenda record;

     2) Increasing the number of addenda records for CTX (and perhaps ENR and TRX) transactions to a number larger than 9,999, or remove the limitation entirely;

     3) Creating additional addenda type codes to provide depository institutions with more information regarding the information they are receiving, such as free text, URL, XML, etc.; and

     4) Establishing service-level requirements for receiving depository financial institutions (RDFIs) to provide the payment-related information in addenda records to their consumer receivers.

•  CUNA is interested in how these addenda record topics may affect credit union operations and compliance on the ACH network.

•  Comments for the request for information are due to NACHA by May 16, 2014; please submit your comments to CUNA by May 5, 2014.

•  If you have any questions or comments, please contact CUNA Assistant General Counsel for Regulatory Research Dennis Tsang at dtsang@cuna.com.

•  For additional background, please visit NACHA’s comment page, this RFI ; and a presentation on these topics

* 1. Does your credit union have any comments or information regarding these four addenda record topics from the NACHA request for information?

* 2. Any other comments or suggestions with addenda records or other related topics on ACH transactions?

* 3. (Optional) What is your credit union's asset size?

* 4. (Optional) Please provide information about yourself and your credit union.

Thank you for your input and time - CUNA Regulatory Advocacy Team