The New York Credit Union Association is conducting a brief online survey to gather credit union feedback on the National Automated Clearing House Association proposal to impose liability on financial institutions that prematurely post ACH payments.
Originating depository financial institutions frequently send ACH payments to receiving depository financial institutions prior to the day the credit is to be made available. However, by sending files earlier than the day the funds are to be made available, the ODFI could potentially recall payments sent in error.
There currently is no penalty for prematurely making ACH payments to consumers, and NACHA is considering proposing a rule to make institutions that make funds available before the date specified by an ODFI be responsible for any harm resulting from a premature payment.
The Association will consider your feedback when drafting a comment letter to NACHA on this proposal. Survey responses are requested by July 14; comments are due to NACHA by July 16.
The Association thanks you for your feedback and participation!