The week of June 18, 2012, the Credit Union National Association (CUNA) submitted a comment letter to NACHA – The Electronic Payments Association regarding their ACH security framework proposal. In CUNA's letter, they urged NACHA to minimize compliance costs on all credit unions and minimize redundancy with other data security requirements. Also, CUNA believes the framework should permit each covered entity to implement ACH security on protected information based on its business and risk needs, help minimize additional compliance costs and burdens, and ensure consistency with other regulatory responsibilities. The ACH security framework should not impose specific requirements, such as specific security policies, procedures, and systems. Further, it urged NACHA to provide a flexible ACH security framework to accommodate the evolving data security landscape, including with mobile and internet applications.