If you haven’t already heard, NACHA announced on May 19, 2015, that its voting membership approved Same Day ACH.
What is Same Day ACH?
While an opt-in Same Day ACH service has existed through FedACH for some time, the lack of ubiquity meant that many of the use cases for same-day ACH were unattainable. With the recent passing of a ubiquitous Same Day ACH rule, the primary use cases now have the potential to become reality.
The advent of same-day ACH capability for virtually any ACH transaction means businesses, governments and consumers will now have options to move money faster. And with the increased demand for faster payments, same-day ACH represents an important step to help modernize the payments system, creating opportunity for future product innovation.
3-Phase Approach to Same Day ACH Implementation
Though it will be optional for Originating Depository Financial Institutions (ODFIs) to offer same-day ACH, all Receiving Depository Financial Institutions (RDFIs) will now be required to accept same-day ACH payments and to make same-day credits available to their depositors.
Under the new rule, two new settlement windows will be added to the ACH Network to accommodate same-day payments. This will increase the movement of funds between financial institutions from once each day to three times per day.
To help businesses and financial institutions like yours to prepare, this new rule will be implemented in a phased approach.
- Phase 1: Credit transactions will become eligible for same-day processing and settlement with availability by the end of the RDFI’s processing day
- Phase 2: Same-day debits will be added, increasing the use cases for same-day ACH
- Phase 3: Credit funds availability requirements for RDFIs will be faster, and same-day ACH credits will need to be made available to customers by 5 p.m. RDFI local time
The Federal Reserve confirmed their support of the Same Day ACH Rule on Sept. 23, 2015. The first phase is scheduled to be implemented beginning Sept. 23, 2016, with the final phase to be completed on March 16, 2018.
What Does Same Day ACH Mean for Bankers?
Same Day ACH means that bankers need to take action to anticipate the changes coming down the pike. With the proposed implementation schedule, bankers like you need to start working with your vendors, like CSI, to determine your bank’s approach to these changes and evaluate potential ACH risks.
Taking action now could help your financial institution avoid potential FFIEC penalties for violating NACHA operating rules.
Greg Aumann is the application product manager for NuPoint ACH. He is responsible for ensuring the application remains competitive and compliant in today’s rapidly changing ACH environment. Greg is an Accredited ACH Professional (AAP) and is also a member of EPCOR’s Education Committee.