The Clearing House Comments on Proposed Changes to Nacha Rules for International ACH Transactions
Nacha requested feedback on potential rule changes regarding International ACH (IAT) Entries and related request for information topics. The proposals included revising the definition of IAT Entry; making IAT Entries eligible for same day processing, settlement, and funds availability; and making potential changes to the IAT Entry format. The Clearing House submitted comments generally in support of revisions to the IAT Entry definition but recommended that Nacha review the proposed definition and examples with the Nacha Lawyers Committee, AML and other compliance experts. Feedback also included support for changes to the IAT Entry format to the extent that the changes utilize the existing fields in the ACH format and do not require significant industry investment. Conversely, TCH did not support making IAT Entries eligible for same day processing, settlement, and funds availability as it is unclear the benefits justify the costs or expanding the IAT format as the industry has already made significant investments in ISO 20022 systems that are better suited for cross-border activity.
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