The Missouri Credit Union Association (MCUA) recently submitted two related comment letters to NACHA – The Electronic Payments Association on Automated Clearing House (ACH) Network Risk and Enforcement Topics and Improving ACH Network Quality. MCUA appreciates that NACHA is taking steps to improve ACH network risk management and enforcement by looking into ways to reduce exceptions and their associated processing costs. Credit unions generally originate higher quality transactions and generally support many of the proposed changes. MCUA also highlights some concerns with potential unintended consequences and recommends more targeted ways to reduce risk. MCUA has asked NACHA to minimize costs on credit unions that may be affected by these proposed changes.