Same-Day ACH – Phase 2

Transmissions Lessons Same-Day ACH - Phase 2

This document provides technical guidance for users of the FLEX system regarding Same-Day ACH – Phase 2 processing, effective September 15, 2017.

1. Overview of Same-Day ACH – Phase 2

Same-Day ACH – Phase 2 expands the Same-Day ACH capabilities to include both debit and credit entries, allowing for the same-day processing of virtually any ACH payment. This phase became effective on September 15, 2017.

  • Key Enhancement: Inclusion of debit entries for same-day processing.
  • Impact: Enables faster processing for a wider range of ACH payments.
  • Network Functionality: Utilizes additional ACH Network functionality without altering existing ACH schedules.

2. Eligibility for Same-Day ACH

Virtually all types of ACH payments are eligible for same-day processing under Phase 2, including both credits and debits.

  • Eligible Transactions:
    • Credits
    • Debits
    • Approximately 99% of current ACH Network volume.
  • Ineligible Transactions:
    • International ACH Transactions (IATs)
    • High-value transactions exceeding $25,000

3. ACH Operator Clearing Windows

Originating Depository Financial Institutions (ODFIs) can submit Same-Day ACH payment files through two additional clearing windows provided by ACH Operators.

  • Morning Submission:
    • Deadline: 10:30 AM (ET)
    • Settlement: 1:00 PM (ET)
  • Afternoon Submission:
    • Deadline: 2:45 PM (ET)
    • Settlement: 5:00 PM (ET)

Note: Actual ACH Operator schedules are not determined by NACHA Operating Rules.

4. Same-Day ACH Fees

A Same-Day Entry Fee is assessed for each origination transaction.

  • Fee Amount: $0.052 per origination transaction.
  • Assessment: Assessed as a surcharge to ODFIs and credited to RDFIs.
  • Collection: Collected by ACH Operators on behalf of RDFIs.
  • Settlement: Settles to ODFIs and RDFIs on a monthly basis.
  • Exemption: ACH returns processed on the same day are not subject to this fee.

5. Identifying Same-Day ACH Transactions

When receiving Same-Day ACH transactions, the primary indicator is the settlement date assigned by the ACH Operator.

  • Primary Indicator: Settlement Date (assigned by ACH Operator).
  • Distinction: The settlement date may differ from the effective entry date.
    • Effective Entry Date: The date the originator intended for the transaction to settle.
    • Settlement Date: The date determined by the ACH Operator based on actual processing time.

6. End of Processing Day Definition (Phase 2)

For Same-Day ACH Phase 2 (September 15, 2017, through March 15, 2018), an RDFI is required to make funds available from a Same-Day ACH credit in customer accounts no later than the end of processing for that settlement date.

  • Credit Availability: Funds from Same-Day ACH credits must be available by the end of the processing day.
  • Usage: Funds must be available to satisfy subsequent debit entries (e.g., ACH debits, checks).
  • Withdrawal: Funds are not required to be available for cash withdrawal (e.g., via Visa or ATM) at this time.

7. Receiving Depository Financial Institution (RDFI) Responsibilities

All credit unions receiving ACH transactions must comply with the new Same-Day ACH rules.

7.1. Step 1: Process Additional File(s)

  • Ensure that future-dated debits are not posted when processing Same-Day ACH debits from additional files.
  • All additional files for ACH processing may contain future-dated items.

7.2. Step 2: Make Funds Available to Members

  • Transactions should be processed based on the settlement date provided by the ACH Operator.
  • It is not necessary to review the effective entry date or other indicators to determine processing or same-day eligibility.
  • Phase 2 Specifics (Effective September 15, 2017):
    • Same as Phase 1, with the addition of Same-Day ACH debits.
    • Funds from Same-Day ACH credits and debits must be available in member accounts no later than the end of processing for that settlement date.
    • Funds must be available to satisfy other subsequent debit entries against the account (e.g., pay ACH debits and checks).
    • Funds are not required to be available for cash withdrawal (e.g., ATM).

7.3. Step 3: Process Returns

  • Returns are allowed (but not required) to be processed on the same day they are received.
  • ACH returns must adhere to normal timeframes.
  • Important Note: Since settlement for Same-Day ACH transactions is one day sooner, the return deadline is also one day sooner. Most items require return within two business days.

7.4. Step 4: Account for Additional Income

  • The Same-Day Fee allows RDFIs to recover costs associated with enabling and supporting Same-Day ACH.
  • The Federal Reserve will pass through fee income monthly.
  • Income Amount: $0.052 per Same-Day ACH item received.

8. Originating Depository Financial Institution (ODFI) Responsibilities

Processing Same-Day ACH transactions is optional for Originators and ODFIs.

8.1. FLEX System Configuration

  • To process Same-Day ACH through FLEX ACH services, a control parameter change is required on your system.
  • For originating Same-Day Debits, a FLEX deployment is required for 8.02 and 8.03 Release Levels before September 15, 2017.
  • If your credit union is not scheduled for a deployment between July 13, 2017, and September 15, 2017, please email training@cmcflex.com to schedule a deployment outside your normal rotation.

8.2. Processing Requirements for Opting-In

If you choose to opt-in for Same-Day ACH, be aware of the following processing requirements:

  1. Effective Date Insertion:
    • The appropriate effective date must be inserted into the ACH transaction.
    • The FLEX System processes ACH transactions based on the effective date entered.
    • If the current date is entered as the effective date and the transaction is submitted prior to the Same-Day origination cut-off time, the transaction will be forwarded to the ACH Operator for same-day processing.
  2. Stale-Dated Transactions:
    • Transactions with stale dates submitted prior to the Same-Day origination cut-off time will also be considered Same-Day transactions.
    • Warning: A batch could be unintentionally processed as same-day if the effective entry date is the current processing date, invalid, or stale, resulting in the assessment of the Same-Day Entry Fee.
  3. ACH Operator Charges:
    • The ACH Operator will charge $0.052 for each Same-Day ACH transaction.
    • Charges are assessed once a month.

9. Important Considerations

  • Effective Entry Date: This field is critical. When a file is submitted by the appropriate deadline, the effective entry date triggers same-day settlement for eligible transactions.
  • Unintentional Same-Day Processing: Be aware that batches with current, invalid, or stale effective entry dates may be unintentionally processed as same-day, incurring the associated fee.

10. Additional Resources

For further information and quick reference guides, please visit the NACHA website: