Request for Comment – Return Efficiencies - Return Time Frames
This Request for Comment (RFC) proposes to shorten the return timeframe for certain returns, based on specific return reason codes. Return reasons included are those that can be decisioned by a processing system without the need for further manual review. Faster returns bestow an ACH Network-wide benefit across many participants.
Additionally, a Request for Information (RFI) is included to determine industry views on potentially shortening the current timeframes associated with dishonored and contested/corrected dishonored returns.
All ACH Network participants are encouraged to provide their comments on this proposal, request for information, and the questions posed. Responses on this RFC/RFI are requested by Friday, June 26, 2026.
Please review the survey questions prior to beginning your response so that you can gather information and comments from all impacted areas of your organization before responding to the questions. You can download the materials on the left side of the page and respond online ACH Participant Survey, End User Survey.
Download materials: Presentation, Proposed Modifications to the Rules, Supplement to Proposed Rules Modification, ACH Participant survey (word version), End User survey (word version).
Details
Request for Comment - Return Timeframes
The proposal would shorten the timeframe for returns that are typically returned without human decisioning or handling by an RDFI. This would result in many returns being sent sooner than is currently the case. While there is no restriction in the Nacha Operating Rules from returning an entry as early as possible, including through the use of the same-day processing windows, a previous Request for Information (October 2024) found that the same-day windows are not widely used to send returns.
Returning debits sooner benefits an RDFIs’ liquidity. For example, an RDFI can get settlement for a debit return on the first banking day after the settlement of the original entry, rather than the second. Furthermore, by transmitting a return sooner, an RDFI mitigates the operational risk of an outage or disruption that might result in a missed deadline. Originators benefit from receiving ACH returns as soon as possible in order to take appropriate actions with respect to the entries or Receivers. Acting sooner can lower the risk of loss, and of originating similar entries prior to remediation. Faster returns, therefore, bestow an ACH Network-wide benefit.
For these reasons, faster returns are one objective of Nacha’s roadmap for the ACH Network.
Impact
Return Timeframes
Effective date – September 15, 2028
Adding a new return timeframe may require an extended implementation period to allow for system updates, industry education, and training.
Anticipated Benefits
RDFIs:
- Improved liquidity as the RDFI would not be carrying unwanted debits over a second night.
- Reduced risk of receiving additional, similar entries that cannot post.
- Reduced operational risk should an RDFI experience an outage or disruption during the overnight hours close to the standard return deadline.
ODFIs/Third-Parties/Originators:
- Faster information regarding unpostable entries, potentially reducing loss.
- Parties can act more quickly to prevent additional transactions and begin recovery/communication with the customer.
Potential Impacts
All Participants:
- Adding an additional, shortened return timeframe to the ACH Rules, beyond the existing standard and extended timeframes, will add complexity to return rules and necessitate training for all parties.
ACH Operators:
- ACH Operators do not edit ACH return entries for timeliness, but some system interfaces or reporting may need updating to provide accurate information based upon a shorter return timeframe.
- Some Operator functionality such as FedLine may require updating to allow for reporting of forward transactions and derivation of return entries prior to the day after settlement.
RDFIs:
- Systems that handle ACH entries and returns, including ACH processing and potentially core systems, will require updates.
- Some systems used to derive ACH returns do not currently make entry information available to RDFIs until the day after settlement, either shortening the amount of time available to RDFIs or necessitating changes to offer derived return capabilities on the settlement date.
ODFIs/Third-Party Service Providers:
- Updates would be needed for those systems that automatically dishonor returns as untimely. If the process is not automated, ODFI staff would require procedural changes, or risk accepting untimely returns.
- Reconsideration of Originator/Third-Party Sender funding requirements for potential returned entries. This may be similar to requirements for Same Day ACH entries initiated late in the day.
- For maximum benefit, the frequency of returns reporting to Originators may need to be increased.
Originators/Third-Party Senders:
- Possible updated funding requirements for potential returned entries.
- For maximum benefit, additional return reports may need to be ingested and acted upon.
