The National Automated Clearing House Association (NACHA) recently adopted new rules that govern Same Day ACH processing. The new 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.
The new rules for Same Day ACH will impact ALL ACH participants, unlike the current FRB same day service which had optional participation. Additionally, the FRB same day service will be discontinued when the NACHA process is implemented later this year.
The implementation process will occur in the following three phases:
|Phase 1||September 23, 2016||includes credits only with funds availability at the end of RDFI’s processing day|
|Phase 2||September 15, 2017||includes both credits and debits with funds availability at the end of RDFI’s processing day|
|Phase 3||March 16, 2018||includes both credits and debits with funds availability required by RDFI at 5:00 pm local time|
Is there a reason why the process starts with credits only?
The decision to start with credits was based upon feedback that NACHA received during an earlier same day proposal in 2012. Credits generally cause fewer exceptions and returns than debits, and therefore are viewed by many as a good way to gain initial experience processing same-day ACH transactions.
Although phase one only focuses on credits you should also begin to consider what impacts phase two debit processing and phase three funds availability may have on your credit union.
Are all ACH transactions eligible for Same Day ACH?
All ACH transactions are identified by their Standard Entry Class code (SEC). All SEC codes are eligible for Same Day ACH except IAT (international ACH) and ENR (automated government enrollment request) transactions. Transactions over $25,000 are also excluded from the new Rule. For phase one, debit entries will not be allowed. All other origination transaction types, returns and notification of changes will be allowed.
Is there a fee to process Same Day ACH transactions?
Yes, a Same Day Entry Fee of $0.052 per origination transaction will be assessed as a surcharge to ODFI’s and credited to RDFI’s to cover the RDFI’s costs of enabling and supporting Same Day ACH. This includes all forward origination transactions including pre-notes but excludes all returns or notifications of change transactions. The Same Day Entry Fee will be collected by the ACH Operators on behalf of the RDFI’s and will settle to ODFI’s and RDFI’s on a monthly basis. ACH returns processed on the same day will not be subject to this fee.
Alloya will not charge any additional fees for originating or receiving Same Day ACH transactions.
How do I know if an item is a Same Day ACH transaction?
When receiving Same Day ACH, the settlement date assigned by the ACH Operator will be the only indicator for Same Day ACH transactions. It should be noted that the settlement date and the effective entry date may be different. The effective entry date is the date that the originator intended for the transaction to settle. The settlement date is the date determined by the ACH Operator and is based on when the originator actually processed the transaction.
There will be an optional company descriptive date field that may show SD1300 or SD1700; however, not all originators may input this data and the ACH Operator will not validate this field. The SD1300 or SD1700 description translates to Same Day and the military time of the file distribution from the ACH Operator, however because this field is optional it should not be relied on by the RDFI for processing.