December 14, 2020

Don’t Be a File Holder


Michael W. Kahn

Michael W. Kahn


File holders, you know who you are, but for those who don’t, allow us to explain. 

Sometimes, organizations originating ACH payments use stale or other invalid dates in the “Effective Entry Date” field. Accidents happen, but some do it routinely or have never implemented the capability to use current Effective Dates. 

With ACH payments like that, there’s a choice to be made. Either process the file normally, which results in Same Day ACH payments, whether intentional or not; or be a file holder, holding the files until after the last Same Day ACH deadline, so it’s processed the next business day.

In just a matter of months, a change is coming that’s going to make file holding more difficult. On March 19, 2021, the new third window for Same Day ACH payments takes effect. It will mean there’s an extra two hours for an ODFI to submit Same Day ACH payments, until 4:45 p.m. ET. That, in turn, means file holders won’t be able to release files at 2:46 p.m. ET. Instead, they’ll have to hold those files even longer—past the afternoon and into the early evening. 

How do you break the file holding habit? Work with those Originators who habitually have bad dates in the Effective Entry Date field. Make it clear to them that going forward, those files are much more likely to be treated as Same Day ACH, whether they intended it or not.

And then follow through. Because file holding is a habit worth breaking. 

For the latest Same Day ACH information, visit Nacha's Same Day ACH Resource Center.