WASHINGTON-In extensive comments to the Federal Reserve regarding proposed changes to Regulation CC in light of the Check Clearing for the 21st Century Act, CUNA and NAFCU raised several concerns. Both groups' comment letters included a long list of subjects they wanted to express their views on from definitions to disclosures to how the amended part of the regulation would work with other provisions. CUNA and NAFCU said that substitute checks in all instances should be considered the legal equivalent of original checks even if there is an error in the MICR line. Additionally, a reconverting institutions failure to print the MICR information from the original check should be considered a violation of the encoding rules under the law. Both groups also asked that the consumer disclosures regarding substitute checks and expedited recredits include the most basic of information to make it easier for the consumer to read. Both organizations also asked that the "business day" time frame be modified to "banking day" in the interest of conformity, among several other issues. View CUNA's full comment letter at www.cuna.org and NAFCU's at www.nafcu.org. Both credit union trade associations also signed onto a joint letter from nearly 40 other financial services providers, including the banking trade associations, a number of individual banks, and others. The final rule must be in place by Oct. 28, 2004.