The American Bankers Association is urging Nacha to reject proposals to create a fourth same-day Automated Clearing House window and to accelerate funds availability for ACH credits, saying both would create challenges for banks.
Nacha currently operates three same-day windows for processing ACH transactions. The organization has proposed opening a fourth window on Monday through Friday aligned with the close of business in the Pacific time zone. It has also proposed changing the current requirement that receiving depository financial institutions make funds available for non-same-day credit by 9 a.m. the next day if the credit is received by 5 p.m. local time. Nacha would eliminate the 5 p.m. deadline and instead require all funds to be made available by 9 a.m.
In a letter last week, ABA said the proposed fourth same-day window creates two major challenges for financial institutions. First, it would operate late in the processing day for banks, which would increase costs as those institutions would need to acquire additional staff for the longer processing day. Second, it doesn’t take into account that the National Settlement Service is closed during the weekend, meaning banks receiving processing requests late Friday would need to provide immediate funds to customers even though settlement would not occur for 48 hours. “Financial institutions are not comfortable about having that level of risk mandated by a Nacha rule,” ABA said.
As for the proposed elimination of the 5 p.m. deadline, ABA said that if the originator wanted credits posted faster, they can send them earlier, use same-day ACH or use a separate instant payments service.
In addition to the items above, ABA submitted a second letter urging Nacha to reject a related proposal to eliminate the two-day ACH credit window, saying such a change would only be cosmetic in nature to make funds appear to move faster. ABA also disapproved of a proposal to encourage same-day processing of returns, saying that many banks use the extra time to research return requests.
