Letter to NACHA on Faster ACH Topics

RE: Request for Information - Faster ACH Topics

Dear Ms. Bondoc:

Thank you for the opportunity to comment on the Nacha Request for Information (RFI) on Faster ACH Topics. We share Nacha’s goal of maintaining an efficient, safe, and timely payments system.

The RFI seeks input on two topics. The first regards shortening the time period allowed between when ACH credits initiate a payment and the Effective Entry Date when funds settlement will occur. The current rules allow for a two-day period. An Originating Depository Financial Institution (ODFI) can send an ACH Credit on Monday with a Wednesday settlement date. The RFI seeks input as to whether this time period should be shortened to a maximum of one day.

We recognize that this timing has caused confusion, making it appear that a payment is delayed or being held up by a financial institution when it is being completed as directed by the ODFI. However, many Originators have relied on this process for decades. The two-day period allows time for errors to be identified and corrected while ensuring that payment is made on the date specified.

The most recent ACH network statistics released by Nacha indicate that 8.4 billion transactions were sent in the third quarter of 2024. The RFI indicates that up to 20% of network activity or approximately 1.7 billion transactions of that quarter’s volume used the two-day window. Making a change to the processing of that many transactions is not worth the effort.

The second topic that Nacha seeks input on regards identifying steps the industry can take to encourage same-day processing of ACH returns. It would be helpful if Nacha could provide some reasons for encouraging this change. Many financial institutions would be burdened by moving to same-day processing of ACH returns. The time currently allowed gives them the opportunity to review transactions in a manner that a same-day return would not allow.

Thank you for the opportunity to provide input regarding the Request for Information. Should you have any questions, please contact Stephen Kenneally at skenneally@aba.com.

Respectfully,

Stephen K. Kenneally SVP, Payments

Letter to NACHA on Faster ACH Topics

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