New Same Day ACH Processing Window

2/2/2021 - By Janice Weisz, AAP

Effective March 19, 2021

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. Currently, the latest that an ODFI can submit files of Same Day ACH transactions to an ACH Operator is 2:45 p.m. ET. This new window allows Same Day ACH files to be submitted to an ACH Operator until 4:45 ET. RDFIs will receive files from this third window by 5:30 p.m. ET, with interbank settlement occurring at 6:00 p.m. ET. RDFIs will need to make funds available for credits processed in the new window by the end of their processing for that Settlement Date.

Impact to Participants

Originators, Third-Party Senders and Third-Party Service Providers

These ACH participants should discuss with their financial institutions whether using the third Same Day ACH window is appropriate for their businesses.

ODFIs

ODFIs will need to determine with their originating customers whether to implement origination in the third Same Day window. ODFIs will need to update their internal processing applications and procedures to accommodate returns processed in the last window.

RDFIs

RDFIs will need to update their internal processing applications and procedures to accommodate receiving late-window Same Day ACH files and sending late-window returns. RDFIs will also need to provide availability for credits received in this window by the end of their processing for that Settlement Date.

Receivers

Receivers, particularly non-consumer receivers, should be prepared to receive ACH debits and credits later in the day. These participants should review their internal procedures to determine whether any changes are required.

For more information, you can visit Nacha’s website at www.nacha.org/rules/expanding-same-day-ach.

Staying in compliance can be challenging, if you have any questions or need assistance preparing for these new Nacha Rules, email me or a member of our Financial Institutions Team so we can help.

About the Author | Janice Weisz, AAP
Janice is a consultant in the Financial Institution Advisory Group at Saltmarsh, Cleaveland & Gund. Janice has been working with financial institutions since 2001 with an emphasis on operations, compliance, audit and internal controls. She currently provides ACH compliance, NACHA compliance, internal audit and other consulting services to the firm’s financial institution industry clients.