MCUL Requests Comment on NCUA and NACHA Proposal 

On Sept. 4, MCUL & Affiliates issued two requests for comment to credit unions.

The first is a proposal by NACHA to clarify distinctions between Return Reason Codes R03 and R04. Currently, Return Reason Codes R03 (No Account/Unable to Locate Account) and R04 (Invalid Account Number Structure) are defined somewhat ambiguously, causing confusion for many Receiving Depository Financial Institutions and resulting in these codes being used interchangeably to convey problems related to account numbering and titling.

The title R03 does not reference its use for a return because of a name mismatch even though the code’s description addresses that specific scenario, similarly as currently written, both R03 and R04 could be used with returns resulting from account number problems. Where account name and number issues are involved, RDFIs are frequently confused as to which return reason code to use. These clarifications would eliminate ambiguity currently associated with the use of these return reason codes and improve processing efficiency for both RDFIs and Originating Depository Institutions by providing clearer return reason messaging. Comments on this proposal are due Sept. 20. The MCUL Comment Call can be found here.

The MCUL is also requesting comments on the NCUA’s proposal to establish a Minority Depository Institution Preservation Program. The program, to be administered by the NCUA’s Office of Minority and Women Inclusion, would consist of outreach efforts, various forms of technical assistance, and educational opportunities to benefit eligible credit unions. Comments on the proposal are due Sept. 30, and the MCUL Comment Call can be found here.

Submissions to Monitor may be emailed. Bryan Laviolette is the editor of Monitor. Contact him by email or call (800) 262-6285, ext. 233. The newsletter of the Michigan Credit Union League is published Monday mornings or Tuesday mornings when Monday is a holiday. There is no Monitor the week after Christmas and the week after the Annual Convention and Exposition. The MCUL reserves the right to edit submissions for clarity and space.
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