N O T I C E
December 12, 2024: Based on this week’s announcement from the NCUA , we now have a black-and-white path forward for changing how CU*BASE assesses NSF and ANR fees, specifically related to the so-called “APSN” (approved positive, settled negative) transactions.
We are currently working on compiling information to be posted on this page during the week of December 16th. This will review and expand on all of the information and recommendations we’ve put forward to date, along with an overview of the software changes we are now planning to make.
Our research showed that the proposed adjustments will require about 900 hours of development and testing work. The technical teams are meeting now to determine what other projects will need to be pushed off the plate while we tackle this work, and what any potential delays might look like. We have no target ETA at this time, but are escalating as a top priority and will use this Kitchen page to give periodic updates on our progress.
In the meantime, we are also working on a best-effort Query/report that should be able to identify at least the bulk of these “APSN” transactions, and a technique for getting this list into our credit unions’ hands for those who wish to proactively refund fees manually. Information on both the development project and this manual analysis/refund method will be posted on this Kitchen page as soon as we fine-tune the details.
UPDATE December 17, 2024: Please note that the Query/report mentioned above is not available in real time and can look back no further than the previous 30 days. Another factor is the time lag between the original approval and when the transaction eventually posts. The technique being used for this “best-effort” report will be slightly different from the one eventually used in the program enhancements, due to additional data elements we will need to capture to more consistently link the approval and final posted transaction. While this is not guaranteed to identify every potential APSN fee instance, if run consistently this report should allow for good-faith review and refunding of fees that are likely the result of an APSN scenario.