WASHINGTON (10/8/15)--CUNA followed up a discussion last week with NACHA-The Electronic Payments Association with a letter highlighting credit union concerns with changes to same-day automated clearing house (ACH) processing. During the meeting, CUNA and NACHA discussed potential burdens that may impact credit unions, particularly smaller credit unions, as a result of the new same-day ACH rules.
NACHA membership approved the changes in May, enabling originating depository financial institutions (ODFIs) that desire same-day ACH processing the option to send same-day transactions to accounts at any receiving depository financial institutions (RDFIs). The Federal Reserve adopted the same changes last month.
In comment periods for both proposals, CUNA expressed concerns with the requirements that all RDFIs have the ability to receive and post same-day ACH payments. CUNA supports the goal of a faster payments system.
However, it is concerned about increased burdens for small credit unions that will rarely use the service, particularly since the rules do not allow any institution to opt out.
During the meeting, CUNA also urged NACHA and the Federal Reserve to send out a public notice and accept comments on the interbank fee charged to ODFIs for using same-day ACH. The rules currently call for a fee of 5.2 cents per transaction, though CUNA believes a higher fee would be more appropriate.
Both NACHA and the Fed have indicated that they may re-evaluate the amount of any interbank fee over a period of time. CUNA urged in the letter that any future considerations to make changes to the interbank fee should be put out for an additional public comment.
Same-day ACH will be implemented in three phases, with Phase I scheduled to begin Sept. 23, 2016. Subsequent phases will add same-day ACH debits to allow for consumer bill payment uses and the introduction of faster ACH credit funds availability.
CUNA asked NACHA to consider how these phases will affect the operations of credit unions, who are already facing numerous compliance burdens.
“CUNA urges NACHA to reconsider compliance deadlines for medium or smaller sized financial institutions to provide adequate time to prepare for this transition and to minimize compliance and cost burdens,” the letter reads.