Letter to Credit Unions No. 16-CU-06
Preparing for Same-Day Automated Clearing House (ACH) Payments
September 2016

NCUA has published guidance to help credit unions prepare for the commencement of same-day Automated Clearing House (ACH) payments. All credit unions that are receiving depository financial institutions (RDFIs) must be in compliance with the new rules and prepared to receive same-day ACH beginning on September 23, 2016. On that day, ACH Operators will begin delivering same-day ACH credit payments to RDFIs twice each banking day. Reasons a credit union member may wish same day ACH include expedited bill payments, same-day payrolls, business-to-business payments, and account-to-account transfers. There is no limit on the aggregate value of a batch of Same Day ACH transactions, however international ACH transactions and large dollar ($25,000+) are not included in same-day ACH.

Clearing Windows
To facilitate same-day ACH payments, ACH Operators will be providing 2 new clearing windows:

  • A morning submission (10:30 a.m. EST deadline; 1:00 p.m. EST settlement)
  • An afternoon submission (2:45 p.m. EST deadline; 5:00 p.m. EST settlement)

This first phase of implementation of same-day ACH will be for credits only.

Next Phases

 

Phase II
September 15, 2017

​Same-day ACH debits will be added to the same-day credit ACH system. RDFIs must be in compliance to receive same-day ACH debits with funds made available at the end of the RDFI’s processing day.

Phase III
March 16, 2018

Funds from same-day ACH credits must be made available by 5:00pm in the RDFI’s local time.

Fees
Originating depository Financial Institutions (ODFIs) must pay an interbank fee of 5.2 cents/transaction to the RDFI for each same-day ACH forward transaction. ACH Operators will collect the fee on behalf of the RDFIs. The fee will settle between the ODFI and RDFI on a monthly basis.

Risk
NCUA warns credit unions in its guidance that while same-day ACH might have some risk mitigating effects on credit and operational risk, it can increase liquidity and fraud risks. Credit unions will have to more closely manage intraday liquidity as well as enhance file delivery and online banking transfer authentication and security controls. Credit unions should also consider “tolerance” limits for same-day ACH orginators.


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