ICBA told Nacha that it generally supports a provision in proposed operating rule updates that would employ ACH as a low-cost account-validation method for originators, though it is concerned with the burden on receiving institutions.
In a comment letter, ICBA cited a provision that would require RDFIs to provide a "yes" or "no" response to prenotifications, which are test transactions that originators use to determine if account information is accurate prior to initiating live entries.
Among its recommendations, ICBA urged Nacha to dialogue with core processors and payments processors on the feasibility of an automated response and whether the proposed March 18, 2022, effective date provides sufficient time to implement changes