NACHA Releases Bulletin on Same Day ACH Phase II

NACHA recently released ACH Operations Bulletin #2-2017: Same Day ACH and Debit Processing to provide information on important aspects and recommended action items for ACH debit processing in a same-day environment. Even those not planning to use same-day processing for ACH debits should take reasonable care to prevent unintentional same-day ACH debits.

The action items highlighted by NACHA include:

  • All Originators should “check and correct” the Effective Entry Dates in ACH transactions they originate, even those that do not intend to make use of same-day debits.
  • All Originators that intend to make use of same-day ACH debits should review their authorization language to ensure that the terms are clear and readily understandable regarding the timing of such debits.
  • All ODFIs should identify and contact Originators that currently use incorrect Effective Entry Dates in their ACH debit transactions, or otherwise act to address such Originators’ use of incorrect Effective Entry Dates.
  • All Third-Party Senders, ACH software vendors, and ACH payment processors should assess their own role(s) in ensuring accurate ACH processing, including the accurate dating of ACH transactions.
  • ODFIs can contact their ACH Operator(s) for additional assistance, tools and reports regarding Same Day ACH.

The bulletin also provides use cases and specific considerations for ODFIs and RDFIs.

Questions? Contact the Compliance Hotline at 1.800.546.4465 or compliance@nwcua.org.

Compliance Question of the Week

Do I have to file an Unclaimed Property report in the state where the member now lives?

As a convenience, if you have property belonging to a member who lives outside the state, you may just file one Unclaimed Property report with the correct agency for your state. The property must be considered incidental, which is defined as ten or fewer properties with a value less than $1,000 by the National Association of Unclaimed Property Administrators (NAUPA).

There are two exceptions to this rule. The first one is for members whose last known address is in California. That property must be reported directly to California. The second exception is for property held in Idaho whose owner’s last known address is not in Idaho. While Idaho does have a reciprocity agreement with most states, the Idaho Unclaimed Property Department recommends that holders report to the state that the property owner is located in.

Related Links:

WA Unclaimed Property FAQ

OR Unclaimed Property FAQ

ID Holder Information Packet

Interested in learning more?

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Your weekly update on the regulatory landscape.

National Credit Union Administration (NCUA)

The NCUA published its Board Action Bulletin, detailing the outcome of its April Board Meeting. During the meeting, the NCUA Board approved a request to revise Illinois’ MBL rule and reported positive net position on the stabilization fund.

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Consumer Financial Protection Bureau (CFPB)

CFPB Director Cordray delivered prepared remarks on the Ocwen Enforcement Action press call. The CFPB filed a lawsuit against Ocwen, seeking relief to compensate consumers for improperly calculated loan balances, misapplied borrower payments, and incorrect escrow payments.

The CFPB announced the finalization of the extension of the effective date for the prepaid accounts rule. The rule was originally supposed to take effect on October 1, 2017, but will now go into effect on April 1, 2018.

The CFPB announced the proposal of a rule that will amend the CFPB’s ex parte rule. The two main updates include a state entity exemption and procedural improvements.

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Federal Trade Commission (FTC)

The FTC announced that it is seeking comment on proposed changes to the TRUSTe’s safe harbor program under the COPPA rule. The amendment proposes that participants conduct an annual internal assessment of third-parties’ collection of personal information from children.

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Federal Reserve Board (FRB)

The FRB finalized a rule that will increase the rate for primary credit at each Federal Reserve Bank. The amendment took effect on April 18, 2017. The FRB also finalized an amendment to Reg D that revises the rate of interest paid on balances maintained to satisfy reserve balance requirements and the rate of interest paid on excess balances maintained at the Federal Reserve Banks.

The FRB released the April 19, 2017 of its Beige Book.

The FRB announced that it will begin Same Day ACH testing in early summer of 2017 to ensure that it is prepared for the Same Day ACH Phase 2 implementation date of September 15, 2017.

The FRB released the meeting minutes of its April 14, 2017 Community Depository Institutions Advisory Council meeting.

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Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of April 20, 2017. The last update prior to this was April 13, 2017.

Questions? Contact the Compliance Hotline: 1.800.546.4465; compliance@nwcua.org.

Posted in Compliance News, Compliance News, NCUA.