The Clearing House submitted a comment letter in response to NACHA’s proposals to improve the quality of the ACH network by creating new return rate limits, increasing its enforcement authority, establishing ODFI-paid quality incentive fees, and clarifying certain parts of the NACHA Rules. TCH issued support for these changes, though noted the need to revise the rules enforcement process to protect legitimate originators that may exceed the proposed limits and to ensure there is an element of materiality to actions based on improper origination. TCH also recommended that NACHA Rules expressly define “proper authorization” to mean that receiver has provided an actual authorization for a debit or credit to his or her account and that such authorization for debit or credit is clear and readily understandable.