NACHA Comment Letter -- December 9, 1997
RE: 31 C.F.R. Part 208; Management of Federal Agency Disbursements; Electronic Funds Transfer Mandate NACHA's comments in response to the notice of proposed rule making issued by the Treasury Department's Financial
Management Service regarding the implementation of the final electronic funds transfer ("EFT") provisions of the Debt Collection Improvement Act of 1996.
Interim Rule
What the Rule Says
Re: Vendor payments No waivers. FYI: Treasury's approach to small businesses concerned about this is that they can accept the
government's purchasing card for products/services rendered as they do any other credit card.
Re: Consumer payments. New recipients that have a bank account will not be entitled to a
waiver. Existing recipients with bank accounts may qualify for two waivers: geographic hardship or physical hardship. The unbanked will have 4 options:
1. Open a bank account (standard or Direct Deposit Too)
2. Receive Federal benefits through state EBT programs where a linkage is possible
3. Accept an Electronic Transfer Account ("ETA" -- see below)
4. Obtain a waiver -- geographic, physical, or financial hardship.
With respect to waivers, it is up to each Federal
agency how the waiver process will be managed. However, the determination of whether a particular individual qualifies for a specific waiver category is primarily the individual's (i.e., they would have to
attest in writing they meet the terms for the waiver).
