<p>WASHINGTON – The Association of Corporate Credit Unions, a trade association for the nation's 33 corporate CUs, agrees with just about everything in the Treasury's interim final rule on Automated Clearing House transactions. Anything that affects ACH is of interest to corporates as they are the primary payment settlement arm for natural person credit unions. The Treasury's interim final rule reflects changes NACHA – The Electronic Payments Association – has made to its ACH rules. The rule addresses four primary areas: affidavit and electronic issues; reinitiation; electronic authorization; and electronic terminals. The interim rule does touch on some key issues for the continued push for electronic over paper in many financial transactions. In the affidavit and electronic communication provision, the interim rule allows for the use of electronic agreements and electronic storage of records in accordance with the Electronic Signatures in Global and National Commerce Act (E-Sign Act). This coupled with the Fed's amendments to Reg E will allow any required writing for any agreement, authorization, affidavit, or record required by ACH to be done in paper or electronic format. The ACCU supports this move. ACCU Executive Director Gigi Hyland stated in its comment letter to Treasury, "the interim final rule does not mandate that documents be executed in electronic form, but instead provides ACH participants with an alternative other than the use of hard copy documentation." ACCU supports the interim rule's limit on the number of times an ACH may be reinitiated due to returns from insufficient funds or uncollected funds. The rule limits reinitiation attempts to two. "This provision provides Receiving Depository Financial Institutions with recourse when an Originating Depositor Financial Institution continues to re-initiate ACH entries returned more than a total of three times ." The ACCU also supported the rule's validation of electronic signatures as authorization as long as they comply with the E-Sign Act. The electronic terminal provision of the interim rule requires that the city and state of a terminal used to initiate a point-of-purchase electronic check payment to be included on the consumer's receipt and printed on the consumer's monthly statements. Again, ACCU agrees with this provision, stating, "the terminal location provides pertinent information on a consumer's statement to readily identify the item." [email protected]</p>