news.cuna.org/articles/107694-fed-adopts-same-day-ach-cus-not-considered-enough-cuna-says

Fed adopts same-day ACH: CUs not considered enough, CUNA says

September 24, 2015

WASHINGTON (9/24/15)--Though the Federal Reserve board announced approval of its same-day automated clearinghouse (ACH) enhancements Wednesday, CUNA believes not enough was done to consider the increased burdens credit unions will face. The changes will become effective Sept. 23, 2016.

 “In comments to NACHA and the Federal Reserve, CUNA expressed concerns with the requirements that all receiving financial institutions have the ability to receive and post same-day ACH payments,” said CUNA Chief Advocacy Officer Ryan Donovan. “While we support the goal of a faster payments system, we believe more could have been done to consider the implementation and other ongoing costs credit unions will face-- particularly our smaller credit unions.”

The rule enables 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).

It requires all RDFIs to participate and would assess an interbank fee to ODFIs of 5.2 cents per transaction.

In its comment letter on the Fed’s proposal, and the original proposal from NACHA- the Electronic Payments Association, CUNA questioned the mandatory participation requirement, as well as the fee set at 5.2 cents, which CUNA says is too low.

CUNA supports the interbank fee as a way to some measure provide relief for the costs that will be imposed on RDFIs, but asked the Fed to explore a higher fee.  

In its July comment letter, CUNA said a higher fee would be appropriate for “credit unions that will incur higher implementation and ongoing costs relative to the small number of same-day ACH payments they will ultimately receive.”

The Fed currently operates a same-day ACH service, and institutions can opt in or opt out of on a monthly basis. The enhancements to the service will be adopted by incorporation of the amended operating rules into Operating Circular 4, which governs Federal Reserve Banks’ ACH services.