Increasing the Same Day ACH Dollar Limit
Comments Due by January 22, 2021
Nacha requests feedback on a proposal for a regular series of three additional increases to the dollar limit on Same Day ACH payments.
The survey may be completed online via surveymonkey at https://www.surveymonkey.com/r/3Q2Z5TZ by January 22, 2021.
Watch a video about the proposals:
Please review the Rules Proposal Description from the Resource list for complete details
Nacha is requesting comments on a proposal for a series of three additional increases to the dollar limit for all Same Day ACH payments.
Since its inception in 2016, enhancements to Same Day ACH have been implemented on a set schedule. In March 2020, the initial dollar limit on Same Day ACH payments was increased to its current level of $100,000. The increase had an immediate impact on Same Day ACH usage, as the average amount of a Same Day ACH payment increased by 40%.
Nacha now seeks comment on additional increases to the Same Day ACH dollar limit. Responses on this proposal are requested by Friday, January 22, 2021.
Please review the Modifications to the Rules from the Resource list for complete technical details
The proposal would increase the Same Day ACH dollar limit on a set schedule over three consecutive years. Industry dialogue and input to date demonstrates a preference for a single rule change with staged increases, rather than individual rule changes. A single rulemaking effort for multiple increases is more efficient than multiple, individual rule proposals, and allows better planning for future states.
The proposed schedule of increases is as follows:
- March 18, 2022 – increase the existing limit of $100,000 to $1,000,000 ($1M)
- March 17, 2023 – increase the limit to $10M
- March 15, 2024 – eliminate the limit; the dollar limit for a Same Day ACH payment would be the same as for a non-SDA payment
The increases would apply to all Same Day ACH payments. ACH credits and debits; consumer and business payments.
The proposal would give Nacha the ability to pause the scheduled effective dates for up to 6 months if operational, risk, or fraud issues arise. A 60-day notice would be given of a pause.
Increasing the dollar limit is anticipated to contribute to ongoing adoption of Same Day ACH.
Existing use cases would be improved by making a greater percentage eligible for Same Day ACH. These include business-to-business payments, tax payments, payroll funding, insurance claim payments, merchant settlement and Same Day Reversals of standard ACH payments including Same Day credits to reverse debits; and Same Day debits to reverse credits.
A greater percentage of ACH payments, and especially ACH dollar volume, would be eligible for Same Day ACH.
- An additional 3.5% of B2B payments will become eligible for Same Day ACH
- The percentage of ACH dollars eligible for Same Day ACH would more than double
- By the last increase, all ACH payments (except International ACHs) would be eligible for Same Day ACH
Each dollar limit increase would result in a larger amount of dollars settling at several times throughout the day –1:00 pm; 5:00 pm, and 6:00 pm (all in ET).
- By March 2022 (the first proposed increase), the industry will have had a year of experience with Same Day ACH payments settling at 6:00 p.m. ET
All ACH participants should understand, analyze and plan for these dollar flows within their organizations.
- What are the potential impacts of higher-dollar Same Day ACH credits settling at these times?
- What are the potential impacts of higher-dollar Same Day ACH debits settling at these times?
ODFIs would need to determine whether to offer higher dollar limits to Same Day ACH Originators.