Nacha Operating Rules

Deadline Date

Rule Status

Rule Status
Proposed Rule

Request for Comment - Same Day ACH

Nacha is proposing two specific amendments to the Nacha Operating Rules.

  •  Add a fourth daily Same Day ACH processing window aligned with the close of the business day in the Pacific Time Zone.
  • Accelerate funds availability for certain non-Same Day ACH credits.

Responses to the RFC topics are requested by Friday, December 13, 2024.

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 (surveymonkey link).

Additional resources - Same Day ACH: Faster Funds Availability - Guidance for RDFIs on Determining Local Time (Aug 21, 2019)

Details

Details

Add a Fourth Daily Same Day ACH Processing Window

The proposal would establish a fourth daily Same Day ACH processing window on Monday through Friday aligned with the close of business in the Pacific Time Zone. 

A fourth daily Same Day ACH window would provide additional time for ODFIs and Originators to initiate Same Day ACH payments. 

  • This could be especially beneficial for ODFIs and Originators in western time zones.
  • Currently, the latest that ODFIs can submit files of Same Day ACH payments to an ACH Operator is 1:45 pm PT; submission times for Originators are earlier. 

Corporate users of ACH consistently say that expansion of Same Day ACH is a top priority.

Accelerate Funds Availability for Certain ACH Credits

  • Currently, the Nacha Operating Rules require an RDFI to make funds available for a non-Same Day ACH credit by 9:00 am in the RDFI’s local time on settlement day, if the credit is received by the RDFI by 5:00 pm local time on the day before settlement.
  • The ACH Operators currently deliver files to RDFIs multiple times daily after 5:00 pm.
    •  For example, FedACH delivers files to RDFIs at 5:30 pm, 10:00 pm, 11:30 pm, and 6:00 am before 8:30 am settlement.
    • Anecdotally, many RDFIs make funds available by 9:00 am for ACH credits received from the ACH Operator in these files but are not required to by the Rules.
  • This proposal would eliminate the 5:00 pm local time receipt condition, so that funds availability would be required on settlement day at 9:00 am in the RDFI’s local time for all non-Same Day ACH credits.

Download materials: Executive summary, Presentation, Proposed Modifications to the Rules, ACH Participant survey.

Technical

Technical

The following are the changes to the Nacha Operating Rules language to affect these proposals:

Add a Fourth Daily Same Day ACH Processing Window

SUBSECTION 3.3.1.2 Availability of Credits That Are Same Day Entries

For a credit Same Day Entry received in the third or fourth same-day processing window, an RDFI must make the amount of the credit Entry available in the Receiver’s account no later than the completion of the RDFI’s processing for that Settlement Date, subject to its right to return the Entry under these Rules. An RDFI is not required to make such funds available for withdrawal on the Settlement Date.

Accelerate Funds Availability for Certain ACH Credits

SUBSECTION 3.3.1.1 Availability of Credits That Are Not Same Day Entries

For a credit Entry that is not a Same Day Entry and that is made available to the RDFI by its ACH Operator by 5:00 p.m. (RDFI's local time) on the Banking Day prior to the Settlement Date, the RDFI must make the amount of the credit Entry available to the Receiver for withdrawal no later than 9:00 a.m. (RDFI's local time) on the Settlement Date

For a credit Entry that is not a Same Day Entry that is made available to the RDFI by its ACH Operator after 5:00 p.m. (RDFI’s local time) on the Banking Day prior to the Settlement Date, the RDFI must make the amount of the credit Entry available to the Receiver for withdrawal no later than the end of the Settlement Date.

Download materials: Executive summary, Presentation, Proposed Modifications to the Rules, ACH Participant survey.

Impact

Impact

Add a Fourth Daily Same Day ACH Processing Window

Anticipated Benefits

  • A new Same Day ACH window would provide greater opportunity for ODFIs and their Originators to initiate SDA payments for an additional 3¼ hours (estimated) every processing day, generating additional Same Day ACH volume.
  • Later hours would be especially beneficial in western time zones.  Currently, ODFIs in the Pacific Time Zone must submit files of SDA payments by 1:45 pm in their local time; cutoffs for Originators are earlier.
  • A new Same Day ACH window would improve a number of existing SDA use cases and potentially enable more returns using the Same Day ACH windows.

 Potential Impacts

  • All RDFIs would have to implement the receipt of Same Day ACH files in this new window and meet the funds availability requirements for SDA credits.
    • On Friday nights, funds availability would be required with settlement delayed until Sunday nights.
  • An RDFI might be in a net-debit settlement position at the settlement time of this new window and might need to arrange sufficient funding.
  • A Receiver might receive a Same Day ACH debit in this new window.  A business receiver, in particular, might need to monitoring account balances during this time period.

Accelerate Funds Availability for Certain ACH Credits

Anticipated Benefits

  • The proposal would accelerate the availability of funds for some volume of next-day ACH credits that currently are received by RDFIs after 5:00 pm local time and not currently made available by 9:00 am RDFI local time.
  • Consumers and businesses might receive earlier funds availability for ACH credit use cases such as payroll, benefits, cashouts, refunds and invoice payments.

Potential Impacts

If not already doing so, some RDFIs would have to change internal processes and procedures to post and make funds available by 9:00 am local time for next-day ACH credits received after 5:00 pm local time, inclusive through ACH credits received in the 6:00 am ET ACH Operator file.

Download materials: Executive summary, Presentation, Proposed Modifications to the Rules, ACH Participant survey.

FAQs Section

FAQs Section