The Clearing House Payments Company submitted a comment letter in response to Nacha’s request for comment on Reversing Entries and Enforcement. Nacha’s Proposal is intended to address the improper use of ACH Reversing Entries (“reversals”), including a 2019 incident in which a Third Party Sender’s reversals to “claw back” direct deposit payments harmed consumers, RDFIs, and the reputation of the ACH network. The Clearing House supports Nacha’s efforts to deter misuse of reversal entries, and generally agree with the Proposal. However, The Clearing House recommended certain clarifications and modifications, including that Nacha provide clarification regarding the expected timing of returns of improper reversals to consumer accounts; and consider an alternate return reason code for returns of improper reversals to commercial accounts.

Download the full comment letter here.