Executive Summary

• &nbspNACHA – The Electronic Payments Association has issued a proposed rule that would provide a new, ubiquitous capability for moving automated clearing house (ACH) payments faster. The proposal would amend the NACHA Operating Rules to enable the option for same-day processing of virtually any ACH payment (for all types of credits and debits) except for international transactions and individual transactions above $25,000. NACHA believes there are many uses of ACH payments for which businesses and consumers could benefit from same-day processing, including business to business, same-day payroll, expedited bill, and account-to-account payments. Currently, most ACH payments are settled on the next business day; current ACH schedules and capabilities would continue to apply to transactions that are not designated as Same Day ACH.

• &nbspClick here for CUNA's detailed summary.

• &nbspComments are due to the NACHA by February 6, 2015; please submit your comments to CUNA by January 23, 2014.

• &nbspFor further details and resources from NACHA, please visit the NACHA website to review their Executive Summary , Proposed Rule Changes, Detailed Presentation , Fact Sheet, and other materials.

• &nbspIf you have any questions or comments, please contact CUNA Senior Assistant General Counsel Luke Martone.

Questions to Consider Regarding the Proposed Rule

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* 1. Does your credit union support the NACHA proposed rule to enable Same Day ACH?

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* 2. Should all Receiving Depository Financial Institutions (RDFIs) be required to receive
Same Day ACH payments to enable ubiquity in the ACH Network?

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* 3. What are the estimated costs for your credit union to enable Same Day ACH, including
with 1) implementation and 2) ongoing costs? For RDFIs, NACHA believes that a large
portion of the implementation costs would likely be incurred by ACH processors, while a
greater proportion of ongoing costs would be incurred by RDFIs.

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* 4. Is your credit union also an Originating Depository Financial Institution (ODFI)? If so, do
you have any comments regarding the costs and benefits of the proposed rule, such as
with new products and services?

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* 5. Do you support the proposed interbank fee paid from ODFIs to RDFIs for Same Day
ACH transactions to help RDFIs recover some implementation and ongoing costs?
NACHA noted 8.2 cents as an example of such an interbank fee.

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* 6. Also, should all ACH payment types (debits and credits) be eligible for Same Day ACH,
except international transactions and transactions above $25,000?

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* 7. Should all RDFIs be mandated to also provide faster funds availability for Same Day
ACH credits, such as by 5:00 pm local time?

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* 8. Regarding the proposed phases and effective dates, do you have comments regarding
the proposed new processing windows? Will the proposed effective dates provide
sufficient time for your credit union to make the necessary changes?

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* 9. Does your credit union currently use a corporate credit union and/or other entities for
ACH processing?

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* 10. Do you have any comments regarding the technical topics, including with identification
of Same Day ACH transactions, or with risk management?

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* 11. Any other comments, suggestions, or concerns?

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

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

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