Moving Payments Faster

What's Coming for Phase 2 & 3 of Same Day ACH

On September 23, 2016, phase 1 of Same Day ACH processing became effective. The revised NACHA operating rules require mandatory participation in Same Day ACH processing.

Credit unions that originate ACH transactions (ODFI) can elect whether or not to participate as an originator. However, credit unions that receive ACH transactions (RDFI) must have the ability to accept additional ACH files each day and post any Same Day ACH items to their member accounts.

Update on each phase:

  • Phase 1, which included only credit transactions, is complete.
  • Phase 2 becomes effective on September 15, 2017. This phase adds debit and government transactions which like the credits, are required to be posted by the end of your processing day. 
  • Phase 3 follows on March 16, 2018. Phase 3 will require that all same day transactions are posted by 5:00 pm local time.

Next steps:

  1. Attend Training: Click here to register for a training session

  2. Implementation: You may want to consider implementing Phase 2 and 3 at the same time or begin to prepare for Phase 3 which could impact your schedule of operations. Click here to read an overview of the changes.

For RDFI’s:

  • Phase 2 now includes debit transactions and government items that may be effective on the same day.
  • Communicate with members regarding posting of Same Day debit Entries
  • Update account disclosures with the posting process for same day items if necessary.
  • Review your Regulation E transaction dispute process. Members may dispute transactions that posted to their account earlier than the agreed upon date with the originator.
  • As with phase 1, the debit and government items should be posted before the end of your processing day.
  • File formats and file availability times will remain the same.
  • Return deadlines will remain the same.
    • You may see an increase in exception or suspense items with phase two because items may now reject for non-sufficient funds.
  • Settlement posting times will remain the same
    • You may see an increase in debit settlement that may impact your end of day positioning with Alloya.
  • Start planning for phase 3 – contact your data processor to learn what changes need to be made to be able to post Same Day ACH items to your member’s accounts by 5:00 pm local time.

For ODFI’s:

  • If you have opted-in to process Same Day ACH transactions, continue to be diligent about using the correct effective date to avoid unintended same day processing.
    • Originators are still required to receive authorization from the receiver prior to processing ACH entries, which includes the effective date. Debit transactions cannot settle prior to their effective date.
  • Origination deadlines will remain the same.

 

 

Download a printable version of the Same Day ACH webpage