news.cuna.org/articles/106006-same-day-ach-proposal-approved-by-nacha-members

Same-day ACH proposal approved by NACHA members

May 20, 2015

HERNDON, Va. (5/20/15)--The membership of NACHA-The Electronic Payments Association Tuesday approved a same-day automated clearinghouse (ACH) rule. The rule enables same-day capability for virtually any ACH transaction.

Currently most ACH payments are settled the next business day. This rule would enable ACH originating depository financial institutions (ODFIs) that desire same-day processing the option to send same-day transactions to accounts at any receiving depository financial institutions (RDFIs).

ODFIs would be able to submit files of same-day ACH payments through two new clearing windows: a morning deadline of 10:30 a.m. (ET), with settlement occurring at 1 p.m. (ET) and an afternoon deadline of 3 p.m. (ET) with settlement occurring at 5 p.m. (ET).

International transactions and individual transactions over $25,000 are not eligible for same-day ACH.

The rule will be implemented in three phases, with Phase I scheduled to begin Sept. 23, 2016:

  • Phase 1: ACH credit transactions will be eligible for same-day processing, supporting use cases such as hourly payroll, person-to-person (P2P) payments and same-day bill pay;
     
  • Phase 2: Same-day ACH debits will be added, allowing for a wide variety of consumer bill payment use cases such as utility, mortgage, loan and credit card payments; and
     
  • Phase 3: Introduction of faster ACH credit funds availability requirements for RDFIs; funds from same-day ACH credit transactions will need to be available to consumers by 5 p.m. RDFI local time.

CUNA expressed concerns with the proposal in its comment letter filed in February, and also suggested a number of changes should the rule be finalized. Several of those changes were included in the final rule, including the two clearing windows.

ODFIs will pay a same-day entry fee of 5.2 cents per transaction, down from the originally proposed 8.2 cents per transaction.

While CUNA continues to have concerns with the rule, it does support ODFIs paying a fee, since it will help credit unions and other small RDFIs that will incur increased costs, while likely only receiving a limited number of same-day ACH transactions.

The Federal Reserve has expressed support for NACHA’s assessment that same-day ACH is critical to the future of the payments system. However, the Fed has also stated that it doesn’t believe the fee will benefit RDFIs.

CUNA signed a joint letter with other trade organizations this year in response to the Fed’s statement, expressing that the higher the fee paid by ODFIs, the better chance smaller RDFIs have at recovering some costs involved with the process.