All credit unions that receive ACH transactions are required to comply with the new Same Day ACH rules. There are a few things you will need to consider as you make adjustments to your policies and procedures to process Same Day ACH transactions.
Step 1: Process additional file(s)
All financial institutions that receive ACH transactions must accept Same Day ACH transactions as of the implementation date, September 23, 2016. On the implementation date, Alloya will distribute ACH receipt files up to three times per day:
|Distribution Window||File Availability|
|Morning||Morning Files will be available by 6:00 am ET|
|Noon||Noon Files will be available by 12:30 pm ET|
|Afternoon||Afternoon Files will be available by 4:30 pm ET|
*All distribution files listed above may contain both same-day and future dated transactions. Times are estimates and are based on ACH Operator file distribution times which can vary.
Your credit union will have the option to receive all three files or just the morning and afternoon files. If the latter option is chosen, then the transactions contained in the afternoon file would include any items from the noon distribution. If there are no transactions for a specific distribution time, then no file will be created for your credit union. Closer to the implementation date, Alloya will ask for your file distribution preference.
Important! Please check with your data processor to ensure that you can import multiple files in a day into your core processing system and generate exception reports at each import. The standard NACHA file formats will not be changing. The files may contain a mixture of both same day items and future dated items. Same day items must be posted before the end of your processing day, while the future dated items may be optionally warehoused and posted on the effective date.
Step 2: Make funds available to your members
You should process transactions based on the settlement date provided by the ACH Operator. You do not need to review effective entry date or any other indicator to determine processing, nor do you need to determine same day eligibility for processing.
• Phase 1, effective September 23, 2016, an RDFI is required to make funds available from a Same-Day ACH credit in its member’s account no later than the end of processing of transactions for that settlement date. While funds do not need to be available for cash withdrawal at that time (e.g. via an ATM), they must be available to satisfy other subsequent debit entries against the account that may process after the afternoon file has been received. (e.g. to pay ACH debits and checks).
• Phase 2, effective September 15, 2017, same as above with the addition of Same-Day ACH debits.
• Phase 3, effective March 16, 2018, RDFIs must make funds available for withdrawal (including cash withdrawal at the teller or ATM as applicable) by 5:00 pm at the RDFI’s local time. RDFIs may make funds available earlier; this time is a “no later than” deadline by which funds must be available. RDFIs always have discretion to make funds available earlier.
Step 3: Process Returns
Returns will be allowed, but not required, to be processed on the same day they are received. You still have to follow the normal time frame for ACH returns, but you should be aware that since settlement is one day sooner for Same Day ACH transactions, the return deadline is also one day sooner. Appendix Four of the NACHA rules states that Return Entries must be received by the ACH Operator by its deposit deadline for the Return Entry to be made available to the ODFI no later that the opening of business on the second Banking Day following the Settlement Date of the original Entry.
Alloya will implement the following cut-off times for processing ACH returns as of the implementation date, September 23, 2016:
|Return Window||Cut-off Time*||Return Settlement|
|Morning||9:30 am ET||Same day settlement by 1:00 pm ET|
|Noon||1:45 pm ET||Same day settlement by 5:00 pm ET|
|Afternoon||7:00 pm ET||Next day settlement by 8:30 am ET|
NOTE: You will now have until 1:45pm ET to submit your ACH return items and receive the settlement on the same business day. Also note that Alloya’s cut-off times may differ from the FRB ACH Operator schedule. This is due to the fact that Alloya will need some time to process files before sending them to the ACH Operator on your behalf.
Return transactions processed according to the cut-off times listed above may include both same day and prior day items as long as the items are returned within their respective time frame according to the return reason and transaction type.
Step 4: Account for additional income
The Rule includes a “Same Day Fee” on each Same Day ACH transaction so that RDFI’s can recover, on average, their costs for enabling and supporting Same Day ACH. The Federal Reserve will pass through the fee income each month in the amount of $0.052 per Same Day ACH item received.
Step 5: Review downstream applications
Review all downstream applications and systems that may be impacted by Same Day ACH. Also review policies, procedures, agreements and disclosures that may need to be updated based on processing changes.
For additional items to consider as a receiver of Same Day ACH transactions, please refer to the NACHA Same Day ACH RDFI Implementation Checklist located on NACHA’s website.
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