While it might be surprising to realize that Same Day ACH went live more than four years ago, ongoing enhancements to this new ACH Network capability have kept the ACH industry busy.
Following the increase in the Same Day ACH dollar limit this past March, a new Same Day ACH processing opportunity arrives in March 2021, at which point “the streak will still be alive of six phases of Same Day ACH becoming effective over six consecutive calendar years,” said Michael Herd, Nacha Senior Vice President, ACH Network Administration.
That upcoming addition of a third Same Day ACH processing window, with an ODFI deadline of 4:45 p.m. ET, was the primary focus of a Sept. 29 ACH Network Town Hall, where Herd was joined by representatives of both ACH Operators, the Federal Reserve and The Clearing House.
Alex Romeo, Vice President and Product Manager for EPN, the ACH Operator of The Clearing House at the time of the town hall, said the two ACH Operators will be the first to conduct tests in advance to ensure all systems work properly.
“We consider that the core of the ACH Network. If the core is good, then the circle starts to expand to include the financial institutions in testing and the third-party service providers,” said Romeo. He called end-to-end testing “imperative.” Both Operators expect to begin customer testing in January.
Romeo also stressed the importance of testing settlement advices for the new window, in addition to file testing.
“It’s not enough just to say you received the new advice from your ACH Operator,” said Romeo. “Take that new advice—please—and run it through a system test. Check the reconcilement and settlement to make sure it’s doing what it’s supposed to do.”
The addition of the third window requires changes to the closing times of both the National Settlement Service (NSS) and Fedwire. There’s currently an hour between closing times, but “we are compressing that time to 30 minutes,” said Pat Hilt, Vice President, Wholesale Product Office, at the Federal Reserve Bank of New York. NSS will stay open an extra hour until 6:30 p.m. ET, and Fedwire an additional half-hour until 7 p.m. ET. Hilt said it still leaves ample time for banks that receive settlement entries from NSS to reposition balances and use Fedwire.
Wendy A. Radford, Subject Matter Expert II, Strategic Business Relations, at the Federal Reserve Bank of Atlanta, noted that in adding the new third window at 4:45, “We did away with the 4 o’clock returns-only deadline.”
“This is not a bad thing, because you’re actually getting 45 more minutes to submit your return entries to the Operator. So, this is a good thing,” said Radford, adding that AJ19 return-only files are going away.
Herd gave a hat tip to both the Federal Reserve and The Clearing House, noting that the two ACH Operators “work closely together to ensure true interoperability for the good of the ACH Network.”
“The new Same Day ACH window couldn’t happen without that type of collaboration between our two operators,” said Herd. “A core strength of the ACH Network is that we have two entities that really put the interests of the ACH Network first and foremost.”
A complimentary recording of the ACH Network Town Hall is available on Nacha’s website. The webinar is worth 1.5 continuing education credits for AAPs and APRPs.