The Clearing House submitted a comment letter to Nacha regarding its Meaningful Modernization proposal (“Proposal”) and a request for information on a potential authorization dispute resolution mechanism (“RFI”). The Proposal is intended to streamline and simplify the ACH user experience and allow new technologies to utilize ACH. TCH supports many aspects of this Proposal, but recommended refinement or clarification on certain areas. With respect to the Request for Information (RFI), TCH does not support a Nacha-sponsored arbitration or similar mechanism that would allow Originators to refute the basis of an ACH return as unauthorized. Among other things, TCH believes such a process is inconsistent with the intended design and operation of the ACH network, would by costly, and would create uncertainty for RDFIs that their returns may not be honored.

Download the full comment letter here.