Compliance: Initial phase of same-day ACH effective Sept. 23

August 16, 2016

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.

More information is available on CUNA’s CompBlog, NACHA’s same-day ACH resource center and the Fed’s same-day ACH resource center.

Questions can also be directed to NACHA at, 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.