WASHINGTON-CUNA has written a comment letter to NACHA-the Electronic Payments Association-requesting that it extend the effective date for its proposed "return reason" codes rule to Sept. 10, 2004. CUNA Assistant General Counsel Michelle Profit wrote that CUNA supports the proposed amendments "for operational efficiency," but changing the effective date would "give all ACH participants sufficient time to make necessary program changes." The current date is March 12, 2004. CUNA supported the alterations of the codes overall, but suggested that the codes do not provide enough information to originating financial institutions. For example, an R12 code is being changed from "Branch Sold to Another DFI" to "Account Sold to Another DFI" to clarify that this Return Reason Code is used to address the sale of a specific account as a branch. However, CUNA said the codes also should be altered to generate a Notification of Change with a correct account, routing and transit number so other ACH participants would know where the entry should go. Additionally, CUNA supported the excused delay clarification so ACH participants know that the definition "applies to catastrophic events and not normal processing problems." The trade association also approved of receiving depository financial institutions being required to audit themselves to guarantee they include the check serial number for Destroyed Check Entries and pointed out that it is consistent with recent rule changes. Finally, CUNA signed off on the ACH Operator request to enlarge certain credit and debit fields for the Automated Account Advise standards entry class code.