Letter to Nacha on the Proposed Enhancements to the IAT Rules

Dear Ms. Bondoc,

On behalf of the American Bankers Association (ABA) I am pleased to submit this comment letter expressing our support for Nacha's seven proposed enhancements to the International ACH Transaction (IAT) framework. As an organization committed to the integrity, efficiency, and security of payment processing, we recognize the importance of these updates in adapting to the evolving landscape of cross-border ACH transactions.

We appreciate Nacha's leadership in developing rules that align with current financial industry needs and regulatory expectations. The IAT framework plays a crucial role in facilitating international payments while ensuring compliance with domestic and global financial regulations. The proposed enhancements demonstrate a proactive approach to improving transparency, reducing administrative burdens, and strengthening the security of cross-border transactions.

The rule proposals were accompanied by a Request for Information on four topics that may be subject to rule writing in the future. The ABA recommends that Nacha not pursue rulemaking on any of the four topics considered.

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