Request for Information - DFI to DFI Messaging

In Q1 2017 NACHA invited respondents to provide information on a concept to utilize the ACH Network for a new, ubiquitous capability to exchange non-monetary messaging between financial institutions. Closed for comment March 24, 2017.

Currently, requests and responses for various types of ACH-related documents and other related information are handled outside of the ACH Network via manual processes. This Request for Information was issued to obtain industry feedback on new, conceptual ACH Network functionality, and to stimulate industry thinking about the uses for moving information. 

 

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Detailed Information

The ACH Network currently supports several types of non-monetary messages
 
  • Prenotification – used to validate account information
  • Notification of Change – corrects routing and/or account information
  • Death Notification – allows federal government agencies to notify FIs of the death of a beneficiary
New non-monetary messages are similar in concept to these existing messages and could lay the groundwork for other enhancements or innovative uses of messaging in the ACH Network, such as:
 
  • Positive responses to a prenotification
  • Request for an ACH credit payment
  • Others that could be identified in the future
For additional details about this concept, please review the Executive Summary (under Related Materials)

The technical subgroup recommended the use of non-monetary ACH Entries with buildable addenda records to pass messages (requests and responses)

  • A Message Entry forward request would contain two addenda records (per request) and the response would maintain the original request addenda, adding two more containing response information
  • Each additional messaging addenda record would provide information to create a trail, “linking” it to the previous entry

Document Repository Concept

  • For documentation requests, the use of a trusted third-party repository could facilitate access to documents

    • The rules groups consider the ACH Operators as entities that should consider the feasibility of maintaining one or more repositories for these functions  

1

Responders would upload the requested document to the repository.

2

Repository would create an encrypted key, inserted into the response addenda record.

3

Upon receipt, the requesting financial institution would utilize the encrypted key to securely access the document

 

The following new ACH format and data elements are being put forth for review:
 
  • New Standard Entry Class Code – MSG
  • Allows for segregation of messaging batches
  • New Entry Description – DFIMESSAGE
  • Allows for batching of messages of different types
  • New Transaction Codes
  • New Addenda Type Codes
  • New Message Type Codes
  • New Response Codes
For additional technical details about this concept, please review the Executive Summary and Technical document (under Related Materials)
A potential rule implementing new formats and processes is considered to have considerable impact

These impacts would be offset by the efficiencies gained by substantially reducing or eliminating manual processes to make and respond to requests, as well as the potential for future innovative uses taking advantage of the groundwork completed

  • While the ACH format work could be accomplished at once, additional systems may need to be interfaced for full automation, as well as procedural and client interface changes
  • Information is being requested on implementation considerations, such as phasing in mandatory use dates, perhaps by message type; and phasing out manual processes
For additional details about this concept including messaging benefits, please review the Executive Summary (under Related Materials)

No FAQs at this time

RESULTS OF THE FEBRUARY 2017 REQUEST FOR INFORMATION ON DFI TO DFI MESSAGING SEPTEMBER 1, 2017

Topic Summary
NACHA issued a Request for Information (RFI) on February 9, 2017, related to a concept to utilize the ACH Network for a new, ubiquitous capability to exchange non-monetary messaging between financial institutions. The request invited respondents to provide feedback on a new, conceptual ACH Network functionality, and intended to stimulate industry thinking about the uses for moving information and documents related to payments. Comments were due by March 24, 2017.

Rulemaking Process
Through dialogue and collaboration, NACHA continuously works with the financial services industry and ACH Network participants to make improvements to the NACHA Operating Rules. An RFI is the step in which NACHA gains feedback on ideas around general concepts for changes in the network. (More information on NACHA's rulemaking process can be found at https://www.nacha.org/rules/rulemaking-process.)

Responses and Respondent Demographics
NACHA received 70 responses to the RFI, including 65 surveys and 5 comment letters. Respondents included:

Survey Responses
Financial Institutions - 52

  • less than $250 million - 9.1%
  • $250 million - $999 million - 10.9%
  • $1 billion - $100 billion - 54.5%
  • Greater than $100 billion - 25.5%

Vendors/processors - 6
Regional Payments Associations - 5
End-users - 1
ACH Operator - 1

Comment Letters
Regional Payments Associations - 3
ACH Operators - 1
Associations representing financial institutions - 1

RFI Results
Industry feedback general consensus was that efficiencies in network processing could be gained by addressing the pain points indicated in the original six use cases identified, and that innovation should be supported in the future.

General Feedback Next Steps
NACHA will take the industry input provided in the DFI to DFI Messaging RFI responses to further quantify volumes and costs currently incurred by participants handling these certain network exception processes and, also, the potential cost savings for financial institutions. Messaging system options will also be explored, along with costs and impacts, as compared to potential benefits. A Request for Comment based upon these findings and subsequent ACH Network rule recommendations may be issued in 4Q 2017.

Concept and Use Cases
The majority of respondents indicated agreement that a financial institution messaging system could reduce or eliminate the costs related to the manual processes associated with the request types indicated in the RFI. Additionally, the industry indicated strong support for mandating a single solution for message handling, thereby ensuring ubiquity and a stronger business case for related network changes.

Where uncertainty lay for approximately 42% of respondents was within the impacts of the potential solution, as compared to the benefits. The industry requested additional support from NACHA in determining a supporting financial business case.

Respondents strongly validated the six use cases identified for candidates for a messaging framework:

  • 90% - Copy of Written Statement of Unauthorized Debit
  • 89% - Copy of proof of authorization
  • 87% - ODFI-initiated request for return
  • 83% - Converted check copy
  • 83% - Additional Originator information
  • 82% - Trace request

Information received indicated less support for the potential future use cases of mandatory Prenotification responses and Request for ACH Credit, and that these may prove to have more complex requirements.

The concept of utilizing a centralized repository to support the exchange of documentation was largely supported by the industry, with additional exploration around design and security requirements needed.

The industry was also largely supportive of strengthening rule language around ODFI-initiated requests for return to eliminate a separate letter of indemnity provision to the RDFI.

Opportunity Size
Results around volumes, times spent doing various activities, and processes varied greatly based upon size; volumes for requests being made and received per month ranged from:

  • Low: 0-5
  • Average: 25-30
  • High: 500
  • Outliers: 10,000-20,000

Requests for proof of authorization and ODFI-initiated requests for return were the top two requests based upon volumes provided.

Most respondents indicated they were performing manual, time consuming processes to determine how/where to send the request and handling duplicate requests, both sending and receiving. The average time spent on activities ranged from 15 to 20 minutes per individual request.

Information provided in this portion of the survey provides the starting basis for the financial business case and further analysis will be focused on these results. Time indicated by respondents as being spent on processes that a messaging system could eliminate will be used in calculating potential industry cost savings.

Technical Aspects
The Technical Aspets portion of the RFI survey was optional to complete; however, of the two thirds of respondents that completed this section, over 85% agreed with the messaging format examples provided in the RFI. Additionally, 68% of these respondents agreed with the concept of mandatory response to all forward requests.

Implementation and Impacts
Feedback reflected that respondents were split when asked about a preference for a single or phased implementation. Responses indicated a moderate amount of impact to implement a messaging system; however comments consistently indicated that the ROI would need to be proven to justify any costs assumed in this realm.