In today’s ever-changing world, everything is moving faster, including Automated Clearing House (ACH) transactions, i.e., electronic payments. As you may be aware, effective September 23, 2016, the National Automated Clearinghouse Association (NACHA) established two new same-day settlement windows for ACH transactions. Until now, ACH transactions typically would settle the next business day. Going forward, payments initiated within the new windows (designated time frames) will be received and settled on the same day.

The new Same-Day ACH rule will be implemented in three phases.

• The first, effective September 23, 2016, will be for credit and nonmonetary ACH transactions.
• The second phase, effective the following year, on September 15, 2017, will be for both credit and debit ACH transactions.

During phases one and two, institutions receiving same-day ACH transactions are required to make funds available to their customers by the end of their processing day.

• Phase 3, effective March 16, 2018, will require your institution to make funds for same-day ACH transactions available to customers by 5 pm local time.

While timely processing of those same-day ACH transactions is not optional for receiving depository financial institutions (RDFIs), offering same-day ACH is optional for those financial institutions that originate ACH transactions. Originating Depository Financial Institutions (ODFIs) should consider both the risks and rewards of offering this new service. Same-day ACH can be seen as an opportunity to replace costly U.S. wire payments and be priced as a premium service.

By the year 2018, with full implementation of the new rule, financial institutions are projected to generate 1.4 billion same-day ACH transactions, a significant increase from today’s volume. Now is the time to gear up for this new initiative, first by reviewing your current procedures and available resources. Note that whether you are an ODFI or a RDFI, your same-day ACH transactions will be debited sooner than they were before. Your institution will need to assess the impact same-day transactions will have on your intra-day liquidity, liquidity risk, and daylight overdrafts.

And, as all transactions continue to move even faster, so too will the erroneous ones. It’s important to note that you’ll have less time to screen your transactions for errors, and less time to correct those errors.

Mercadien provides regulatory compliance advisory services to help banks adjust to new requirements and ensure policies and procedures are in place to manage and address upcoming changes that will affect your institution. For more information about the new same-day ACH rule and requirements and help with your preparations for it, contact me at lthouin@mercadien.com or 609-689-9700.