The American Bankers Association on Friday provided feedback to NACHA on its proposed plan to increase the dollar limit for same-day ACH transactions. NACHA proposed to phase-in the increases over three stages, with the threshold increasing from $100,000 to $1 million in March 2022, then to $10 million in March 2023 and finally to the standard ACH limit of $99,999,999.99 by March 2024.
ABA strongly supported increasing the level to $1 million as proposed, but raised concerns about the potential increases in fraud and operational risk that could arise as a result of the subsequent proposed increases. As NACHA proceeds with the second planned increase, ABA advocated for a “circuit breaker” that would allow NACHA to pause any further increases on short notice.
ABA urged NACHA only to move ahead with the third and final increase “only after an extensive circuit breaker review process that takes into consideration the risk associated with raising the transaction limit by $90 million per transaction. If it is determined the increase will create a significant risk, then implementation should be deferred.”