Expanding Same Day ACH
This new rule expands access to Same Day ACH by allowing Same Day ACH transactions to be submitted to the ACH Network for an additional two hours every business day. The new Same Day ACH processing window will go into effect on March 19, 2021.
Creates a third Same Day ACH processing window that expands Same Day ACH availability by 2 hours
- Currently, the latest that an ODFI can submit files of Same Day ACH transactions to an ACH Operator is 2:45 p.m. ET (11:45 a.m. PT)
- The new window will allow Same Day ACH files to be submitted until 4:45 p.m. ET (1:45 p.m. PT), providing greater access for all ODFIs and their customers
- The timing of this new processing window is intended to balance the desire to expand access to Same Day ACH through extended hours with the need to minimize impacts on financial institutions’ end-of-day operations and the re-opening of the next banking day
The precise timing of ACH file processing schedules, including this new third Same Day ACH processing window, are not set in the Rules, but instead are determined by each ACH Operator.
The following changes to technical language represent modifications to the Nacha Operating Rules:
- Article Three, Subsection 18.104.22.168 General Rule for Availability of Credits: To address funds availability requirements for credit Same Day Entries received in the third same-day processing window
- Appendix Three, Glossary of Data Elements, Company Descriptive Date: To include the optional indicator for Same Day ACH entries that the Originator desires to settle in the third window.
Effective Date - March 19, 2021
Final implementation of the new Same Day ACH processing window is contingent upon receiving timely notification from the Federal Reserve Board of Governors of changes to Federal Reserve services necessary to support it. The Federal Reserve process includes a public comment period on changes to the Federal Reserve’s National Settlement Service for interbank settlement and to Fedwire Funds
This Rule creates a third Same Day ACH processing window that expands access to Same Day ACH for all financial institutions by 2 hours.
Currently, the latest that an ODFI can submit files of Same Day ACH transactions to an ACH Operator is 2:45 p.m. ET (11:45 a.m. PT). The new window allows Same Day ACH files to be submitted until 4:45 p.m. ET (1:45 p.m. PT), providing greater access for all ODFIs and their customers by 2 hours.
Interbank settlement for these entries would occur at 6:00 pm ET.
An RDFI will be required to make funds available for Same Day ACH credits in this new Same Day ACH processing window no later than the end of its processing day. This uses the same end-of-day requirement as did Phases 1 and 2. An RDFI could decide to make funds available sooner than the deadline.
Same Day ACH transactions in this third Same Day ACH processing window will be identified in the same way as with the existing windows – by including a “today’s date” in the Effective Entry Date field, and submitting the transaction timely to the ACH Operator.
ODFIs and Originators optionally may use the convention “SD1800” in the Company Descriptive Date field for transactions in this new Same Day ACH window.
All credits and debits, and all returns, will be eligible to be processed in the new Same Day ACH window, except international ACH transactions (IATs) and forward transactions over the per-transaction dollar limit.
All returns (and Notifications of Change) will be eligible for processing through the third Same Day ACH processing window.
The existing “returns-only” window provided by the ACH Operators will be absorbed into the new Same Day ACH processing window. This will enable RDFIs to send returns later into the day, up to 4:45 p.m. ET / 1:45 p.m. PT. It will also create a greater ability for RDFIs to make use of Same Day ACH processing for returns, which would get settled 14.5 hours earlier than next-day returns.
Two hundred twelve parties responded to the Request for Comment. Feedback received demonstrated industry support for expanding the capabilities of Same Day ACH.
ACH end-users unanimously said they want expanded hours and higher dollar limits
A significant majority of financial institutions supported a third processing window
The Rule includes several changes from the original proposal. The changes were made based on input from the industry.
The timing of the new third Same Day ACH processing window was shifted a half-hour earlier to minimize the impact to financial institutions’ end-of-day operations and the re-opening of the next banking day
Some financial institutions responded to the RFC stating that 2 hours are needed between the close of a banking day, and the re-opening of the next banking day at 9:00 p.m. ET (6:00 p.m. PT) when Fedwire re-opens
The timing of the proposed new window allows for the closing of Fedwire by 7:00 p.m. ET (4:00 p.m. PT), thereby allowing the 2 hours desired
The effective date for the new third processing window was changed to September 18, 2020. This is the date that can be supported operationally by the Federal Reserve ACH Operator; and many other RFC respondents requested additional implementation time. (This date was contingent on receiving timely notification regarding Federal Reserve services. The effective date has been delayed until March 19, 2021.)
The funds availability requirement for the existing first Same Day ACH processing window was changed from 1:00 p.m. to 1:30 p.m., as some RDFIs said a little additional time would be necessary to make this possible
The effective date for the funds availability requirements is September 20, 2019, which provides RDFIs approximately one year to implement
An additional proposal in the RFC to require funds availability for other non-Same Day ACH credits by 1:00 p.m. was not pursued
There are no changes to the proposal to increase the per-transaction dollar limit