Letter to NACHA on Same Day ACH Request for Comment

RE: Request for Comment – Same Day ACH

Dear Ms. Bondoc:

Thank you for the opportunity to comment on the Nacha Request for Comment (RFC) to adopt a fourth Same Day ACH Window aligned with the close of business in the Pacific Time Zone. This change would benefit Originators and Originating Depository Financial Institutions (ODFIs) on the West Coast by creating a new Same Day ACH window that would extend the ACH processing day by three hours and 15 minutes.

The RFC also asks the industry to provide input on a proposal to accelerate the availability of funds for non-Same Day ACH credits that are received after 5 p.m. by making them available at 9 a.m. the next day. Currently, entries received after 5 p.m. do not need to be made available at 9 a.m. the next day.

The American Bankers Association recommends that both of these amendments to Nacha Operating Rules be rejected.

The first proposal creates two major challenges for financial institutions. The first is that the proposed fourth window occurs late in the processing day for financial institutions. The late settlement time of 10 p.m. is problematic for banks in the Eastern Time Zone where downstream activities such as positive pay decisions, account sweeps, and standing orders for outgoing wires would all need to be completed in a compressed time frame. This would increase costs for all financial institutions that would also be challenged to obtain staff for this longer processing day.

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Letter to NACHA on Same Day ACH Request for Comment

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Letter to NACHA on Same Day ACH Request for Comment

In Depth

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