WASHINGTON–NAFCU told the Federal Reserve that when it comes to its proposed enhancements to its same day ACH service it has concerns over the impact it will have on smaller credit unions.
As a result, NAFCU is asking the Fed Board to reevaluate the calculation of the interbank fee and consider the recovery of opportunity costs for Receiving Financial Institutions (RDFIs).
“NAFCU understands that this Request for Comment was released in conjunction with the announcement that NACHA’s members voted to finalize amendments to the NACHA operating rules and guidelines for processing ACH Payments,” NAFCU said in its letter. “The new operating rules will require that all financial institutions that send or receive ACH payments implement the capability to process those payments on the same day starting in September 2016.”
NAFCU said it recognizes that ubiquitous Same Day ACH capability represents a significant improvement for the nation’s payment system, but it continues to have significant concerns regarding the Board’s proposed interbank fee and cost-recovery for RDFIs.
“NAFCU and our members believe that the Federal Reserve Banks must act as the Same Day ACH operator in order to ensure ubiquity, public benefit, and long-term cost recovery, however, we believe a few changes must be incorporated into the final Federal Reserve Bank operating rules to ensure feasible implementation by RDFIs,” the trade group said. “As proposed, the cost-recovery mechanisms contemplated by the Board will disproportionately impact smaller financial institutions that will be mandated to provide this Same Day service without adequate compensation.”
In its letter NAFCU raises its concerns with the mandatory participation of RDFIs, the interbank fee, and risks related to fraud. The full text of the comment letter can be found in CUToday.info’s Open Vault here.