Writing a Rule: From Comment to Implement

This course begins with a look at the role of Nacha's Rules and Operations Committee, the journey from idea to implementation – including Request For Comment (RFC) and ballot processes – and how private sector rule-making is key to the ACH Network's success. Following the lecture, students are asked to brainstorm a rule they would like to see implemented and are asked to present a business case for that rule, including implementation impacts to ACH participants to include systemic and opportunity costs, and a recommendation for how long an implementation period would be needed were the rule to be passed.