CUNA weighs in on same-day ACH limits, adding 3rd window

January 26, 2018

CUNA supports adding a third same day automated clearing house (ACH) processing window but remains concerned about utility versus cost that some credit unions may incur, it told NACHA-The Electronic Payments Association in a letter Friday. CUNA responded to a series of questions posed by NACHA regarding same-day ACH.

Same-day ACH was developed by NACHA, and adopted by the Federal Reserve, with the final phase of implementation beginning in September 2017.

The topics covered in NACHA’s survey, and CUNA’s responses, are:

  • Adding a third same-day processing window, which CUNA supports. Though adding the window will likely requires some credit unions to dedicate additional resources, since staff and processes for two windows are already present, CUNA estimates nominal costs;
  • Faster funds availability, which CUNA generally supports, but believes a potential downside is increased fraud incidence could become an issue if payees are required to receive access to funds before all desired security screens can be completed;
  • Increasing the same-day ACH per-transaction limits, which CUNA supports increasing to $100,000 (up from $25,000) for business-to-business and payroll transactions; and
  • Weekend and holiday processing, which CUNA believes may be more burdensome than adding a third processing window. CUNA asks that NACHA closely review survey responses pertaining to the cost of adding weekend and holiday processing, particularly for smaller institutions.