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Maribel Bondoc Manager, System Rules NACHA, The Electronic Payments Association

New Economy venture (formerly NEDAP) is a resource and advocacy center located in New Yark City that actually works to advertise community economic justice and also to expel discriminatory economic techniques that damage communities and perpetuate inequality and poverty. The Virginia Poverty Law Center (VPLC) is an organization that is non-profit serves Virginia’s appropriate aid system by giving advocacy, training, and litigation support on civil justice conditions that affect low­ income Virginians. We many thanks for the chance to submit remarks in the proposed amendments to the NACHA Operating Rules regarding third-parties into the ACH community.