Compliance: Initial phase of same-day ACH effective Sept. 23
Sept. 23 is the implementation date for the first phase of same-day automated clearing house (ACH) service, as finalized by Federal Reserve and NACHA – the Electronic Payments Association. NACHA finalized its same-day ACH rules in May 2015, and the Fed adopted the rules in September 2015.
The rule will enable ACH originators that want to utilize same-day processing the option to send same-day ACH transactions to accounts at any receiving depository financial institution (RDFI). Offering same-day ACH products and services will be optional for ACH originators, but receipt of same-day entries will be required for RDFIs.
The rule includes a “same day fee” on each same-day ACH transaction to allow RDFIs to recover some of their costs for enabling and supporting mandatory receipt of same-day ACH transactions.
Originating depository financial institutions (ODFIs) will be able to submit files of same-day ACH payments through two new clearing windows provided by the ACH Operators:
A morning submission deadline at 10:30 a.m. (ET), with settlement occurring at 1 p.m. (ET); and
- An afternoon submission deadline at 2:45 p.m. (ET), with settlement occurring at 5 p.m. (ET)
Virtually all types of ACH payments, including both credits and debits, will be eligible for same-day processing. Only international transactions and high-value transactions above $25,000 will not be eligible.
The rule becomes effective in three phases:
Phase 1, effective Sept. 23, includes credits only with funds availability at the end of the RDFI’s processing day;
Phase 2, effective Sept. 15, 2017, includes both credits and debits with funds availability at the end of the RDFI’s processing day; and
- Phase 3, effective March 15, 2018, includes both credits and debits with funds availability required by the RDFI at 5 p.m. local time.
Questions can also be directed to NACHA at SDAquestions@nacha.org, or to FedACH customer support at 1-877-372-2457.
The Fed came to CUNA’s Washington, D.C. office earlier this year to discuss its various payments initiatives, including same-day ACH. CUNA is a member of the Federal Reserve’s Faster Payments and Secure Payments task forces.