Request for Comment: Improving ACH Network Quality by Reducing Exceptions

ACH Participant Survey, November 11, 2013, Page 7

Improving ACH Network Quality by Reducing Exceptions

ACH Participant Survey

November 11, 2013

Comments Due by Monday, January 13, 2014.

NACHA requests comments on a proposal to amend the NACHA Operating Rules entitled “Improving ACH Network Quality by Reducing Exceptions.” Comments are due by January 13, 2014.

The survey should be completed online at https://www.nacha.org/page/request-comment

by January 13, 2014. For convenience, the survey questions are also provided within this document to assist respondents in gathering information from within their organizations.

NACHA Staff Contacts

Administrative questions: Maribel Bondoc, Manager, Network Rules

Fax (703) 787-0996

E-mail:

Questions: Peter C. Hohenstein, Senior Director – ACH Network Administration

E-mail:

Section I - Respondent Information

All Respondents Provide

Name
Title
Organization
Phone
Email
Please indicate your organization’s role(s) in the ACH Network:
ODFI / Regional Payments Association
RDFI / Direct FI Member
ACH Operator / Government
Originator / Third Party Service Provider
Receiver / Software Vendor
Other:
What areas of your organization provided input for the responses to this survey?
Operations / Wholesale/corporate banking/treasury mgmt.
Product managements / Customer service
Legal / Compliance
Information Technology/software / Retail/online banking
Other:

Financial Institution Respondents

Asset Size / less than $250 million
$250 million - $999 million
$1 billion - $100 billion
Greater than $100 billion

Section II: Request for Comment

General Questions / Yes / No / Don’t know / No opinion
1.  Does your organization agree that the ACH Network should adopt economic incentives to incent higher-quality origination?
2.  Do you agree that RDFIs should be compensated (whether in whole or in part) for the costs of handling ACH exceptions?
Topic # 1 – Erroneous Data Fees / Yes / No / Don’t know / No opinion
3.  Do you agree with the concept of an Erroneous Data Fee?
If yes, do you agree that the fee should be within the range of $0.10- $0.40 per return?
Higher / Lower / Don’t know / No opinion
If no, should the fee be higher or lower?
Do you have a specific amount to suggest?
Yes / No / Don’t know / No opinion
4.  Do you agree with the specific return reasons included in the Erroneous Data Fee?
5.  Do you agree that the fee should apply to all returns with those specific return reasons?
6.  Do you agree that check conversion transactions (ARC, BOC, POP) should be included within the scope of an Erroneous Data Fee?
7.  Please provide any other comments:
Topic # 2 – NOC Fees / Yes / No / Don’t know / No opinion
8.  Do you agree with the concept of an NOC Fee?
If yes, do you agree that the fee should be within the range of $0.25- $0.75 per NOC?
Higher / Lower / Don’t know / No opinion
If no, should the fee be higher or lower?
Do you have a specific amount to suggest?
Yes / No / Don’t know / No opinion
9.  Do you agree with the specific change reasons included in the NOC Fee?
10.  Do you agree that the fee should apply to all NOCs with those specific change reasons?
11.  Please provide any other comments:
Topic #3 – Unauthorized Entry Fees / Yes / No / Don’t know / No opinion
12.  Do you agree with the concept of an Unauthorized Entry Fee?
If yes, do you agree that the fee should be within the range of $1.50- 2.50 per return?
Higher / Lower / Don’t know / No opinion
If no, should the fee be higher or lower?
Do you have a specific amount to suggest?
Yes / No / Don’t know / No opinion
13.  Do you agree with the specific return reasons included in the Unauthorized Entry Fee?
14.  Do you agree that the fee should apply to all returns with those specific return reasons?
15.  Please provide any other comments:
Yes / No / Don’t know / No opinion
16.  Do you agree that returns for insufficient or uncollected funds should not be covered within the scope of Quality Fees?
17.  Please provide any other comments:

Section III – Impacts and Proposed Implementation Dates

Impacts

RDFIs Only Answer

As an RDFI, what is your fully-loaded operational cost for your institution to handle the following exceptions? Please check the appropriate box. If you have an exact amount, please enter it into the appropriate box in place of a checkmark, as shown in the example below. (Please delete or overwrite the example when responding.)

$0.01 or less / $0.02 - $0.10 / $0.11 - $0.25 / $0.26 -$0.75 / $0.76 - $1.50 / Greater than $1.50 / Don’t know
18.  A Return for Erroneous Data
19.  Initiating an NOC / Example: $0.17
$1.00 or less / $1.01 - $2.50 / $2.51 - $5.00 / $5.01 - $10.00 / $10.01 - $25.00 / Greater than $25.00 / Don’t know
20.  A Return for Unauthorized Entry

All Respondents Answer

On a scale of 1-5 (with “1” representing no systems/software impact, and “5” indicating extensive systems/software impact), please indicate the estimated impact to your organization related to the following proposals:

1 =
No impact / 2 = Minimal impact / 3 = Moderate impact / 4 = Large impact / 5 = Extensive impact / Don’t know / No opinion
21.  Erroneous Data Fee
22.  NOC Fee
23.  Unauthorized Entry Fee
Which of your systems would be impacted? / Core/ DDA & TDA / ACH / Exceptions /returns / Procedures /staff training / Database/ tables / Other systems / Don’t know
24.  Erroneous Data Fee
25.  NOC Fee
26.  Unauthorized Entry Fee
Anticipated cost of the impact by proposal: / Less than $10,000 / $10,000 - $49,999 / $50,000 - $99,999 / Greater than $100,000 / Don’t know
27.  Erroneous Data Fee
28.  NOC Fee
29.  Unauthorized Entry Fee
Does the benefit of the proposal to the Network outweigh the potential impacts and cost to implement? / Yes / No / Don’t know / No opinion
30.  Erroneous Data Fee
31.  NOC Fee
32.  Unauthorized Entry Fee
33.  Please provide any comments on impacts of this proposal:

Proposed Effective Date

34.  Does your organization support the proposed effective date of March 20, 2015 for the proposed changes related to Improving ACH Network Quality by Reducing Exceptions? / Yes
No
Don’t know
No opinion
If “no”, what effective date would you support? / September 19, 2014
September 18, 2015
March 18, 2016
Other? Please specify:

Section IV - General

35.  Please identify any other specific issues that have not been addressed elsewhere in this ACH Participant Survey:

Section V – Request For Information

Prenote Validation Fee / Yes / No / Don’t know / No opinion
36.  Does your organization think there is merit in developing a new type of NOC (with its own Change Code) to indicate to the ODFI that the account information in the prenote is valid?
If yes, should RDFIs be compensated for responding to the prenote with the new NOC?
If yes, should the level of compensation be the same as that being proposed for the NOC Fee?
Higher / Lower / Don’t know / No Opinion
If no, should the amount be higher or lower than the proposed NOC Fee?
Yes / No / Don’t Know / No Opinion
37.  If you do not support a new NOC Change Code, would you support a new type of prenote with a mandatory response required?
38.  Please provide any comments on prenotes and responses: