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NAFCU is seeking members' input on NCUA's proposed requirements for examination sites by Jan. 9 and two proposed amendments to the operating rules of NACHA – The Electronic Payments Association by Jan. 10.

Input from members will be used in the formulation of NAFCU's official comments on these proposals.

NAFCU's regulatory alert on NCUA's proposed rule would specify where examinations and other contacts with agency staff can take place. Among the highlights:

• for the first two years after the proposed rule is finalized, examinations and contacts between NCUA staff and federal credit union staff must occur in a federal credit union's business offices or other public locations and not in a residential location or private home office;
• starting two years after the proposed rule is finalized, federal credit unions would then be required to obtain and maintain a business office, not located on the premises of a private residence address; and
• all federal credit unions would be required to maintain either an email address or telephone number for business purposes.

The proposed rule was released for comment by the NCUA Board Dec. 12.

NAFCU is also requesting members' comments on two NACHA proposals designed to improve network quality and reduce fraud by decreasing the number of automated clearinghouse exceptions. In its regulatory alert, NAFCU highlights that the proposals aim to improve origination practices by placing more responsibility on the originating depository financial institutions. NAFCU is seeking comments on certain aspects of the proposed amendments, including the proposed return rate thresholds and incentive fees.