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You are encouraged to download and respond to NACHA on the following Requests for Comment. For more information you may contact Brad Smith in the Richmond Office 800-681-4224 x104.

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Current Requests for Comment


Adjusting Posting Times for Debits and Credits
The Federal Reserve Board (FRB) issued a request for public comment on a proposed change to the daylight overdraft posting rules under its Payments System Risk (PSR) policy to align the posting times for ACH credit and debit transfers in the payments system [Docket OP-1310].

Under the current posting rules, commercial and government ACH credit transfers processed by the Federal Reserve Banks' FedACH service are posted at 8:30 a.m. ET, while commercial and government ACH debit transfers are posted at 11:00 a.m. ET.  The FRB proposes to change the posting time for commercial and government ACH debit transfers that are processed by the Reserve Banks' FedACH service to 8:30 a.m. ET to coincide with the posting time for commercial and government ACH credit transfers.  In line with this change, the Board also intends, in consultation with the U.S. Treasury, to move the posting time for Treasury Tax and Loan (TT&L) investments associated with Electronic Federal Tax Payment System ACH debit transfers to 8:30 a.m. ET to maintain the simultaneous posting of ACH transactions and related Treasury transactions.

Comments are due at the FRB by June 4, 2008 and information for commenters is included in each policy statement (see links below).  NACHA will be analyzing this proposal further and commenting to the FRB, and we encourage NACHA members to share their views or any questions about this proposal with Carrie Lee or me in advance so that they may be considered in our response.

Separately, the FRB also requested comments on proposed changes to its PSR policy that are intended to loosen intraday liquidity constraints and reduce operational risk in financial markets and the payments system [Docket OP-1309].  

For a copy of either policy statement and request for comment, go to:

ACH Posting Change
http://www.federalreserve.gov/newsevents/press/other/other20080228b1.pdf

PSR Policy re: Intraday Liquidity and Operational Risk
http://www.federalreserve.gov/newsevents/press/other/other20080228a1.pdf

Previous Requests for Comment
ACH Audit and Risk Management Assessment
Audit Rules Description
Audit - Proposed Modifications to the Rules
Audit - ACH Participant Survey
Risk Mgmt - Rules Description
Risk Mgmt - Proposed Modifications to the Rules
Risk Mgmt - ACH Participant Survey
Risk Mgmt - Executive Summary

Although EastPay does send in comments on behalf of our membership, we strongly recommend that you respond to the Request for Comment on your own, especially the Survey. Your opinion does make a difference in the rules process.

Transaction Origin Identification Proposal – A Component of the Risk Management Strategy
Executive Summary
Rules Proposal Description
Draft Rules Pages
ACH Participant Survey
ZIP File with all documents
 
Back Office Conversion
Executive Summary - Attachment A
Research Results and Education Plan - Attachment B
Complete Rules Description - Attachment C
Draft Rules Pages
Survey - Attachement E
 
OFAC & Operator Related Changes to the ACH Network
Request for Comment
Proposed Rules Pages
Cross Border File Format
Appendix B
Appendix C
Appendix D
Participant Survey
ZIP File of all Documents

Operational Efficiencies
Request for Comment
Draft Rule Pages
Survey

Network Return Entry Fees
This popular topic has drawn the attention of all ACH participants. To view EastPay comments on this and to view our survey download the following documents.

EastPay's Comments on Network Return Entry Fees
Our Comments
Our Survey