• Same Day ACH


► What is the Same Day ACH rule?

Over the past several years, NACHA (The National Automated Clearing House Association) has worked with the financial services industry, companies and governments to accelerate ACH payments.

The new NACHA rule requires that ACH-capable financial institutions be able to receive Same Day ACH credits beginning this fall. The program will be expanded in 2017 to include debits.

► Will First Business be able to send Same Day ACH payments to other banks?

Yes. First Business will send Same Day ACH payments to other financial institutions beginning November 1, 2016. First Business will also be able to receive Same Day ACH items. First Business is currently planning a Same Day ACH origination processing deadline of 9:00 a.m. and a 2nd late window of 12:00 p.m CT cut-off. Phase 1 is limited to ACH credits and non-monetary entries ($0.00 pre-notes), with funds available at the end of the Receiving Depository Financial Institution’s (RDFI) processing day.

► Are there dollar limits for Same Day ACH Payments? Any other limits?

Yes. Each individual inter-bank, Same Day ACH payment will be limited to $25,000 domestic ACH transactions; International ACH (IAT) transactions are excluded.

All conforming items in the batch will be originated on a same-day basis, if the file has arrived before the deadline and passes all other ACH edits. The $25,000 limit applies to individual transactions and not to the batch total.

► What is the roll-out schedule for Same Day ACH functionality?

Phase 1 | November 1, 2016 | Same Day ACH payment will be limited to $25,000 domestic ACH transactions; International ACH (IAT) transactions are excluded. The new Same Day ACH rule will limit payments to credit origination transactions. The program will expand to include debits beginning September 15, 2017. Phase 1 is limited to ACH credits and non-monetary entries ($0.00 pre-notes),with funds available at the end of the Receiving Depository Financial Institution’s (RDFI) processing day.

Phase 2 | September 15, 2017 | Addition of ACH debits to same-day processing capability.

Phase 3 | March 16, 2018 | ACH credit funds availability will be updated to 1:00 p.m., Receiving Depository Financial Institution (RDFI) local time.

► Are banks required to be able to send Same Day ACH payments under the rule?

No. The rule requires that banks be able to receive and process same day payments in specific windows. The ability to send Same Day ACH payments is OPTIONAL for banks.

► Will government payments be eligible for same day processing?

The federal government will not be participating in phase one of Same Day ACH. According to the U.S. Treasury, any ACH transaction originated from, or received by, the U.S. government will not be eligible for same day settlement, and will continue to settle on a future date regardless of submission date and time. This limitation applies only to federal government payments, and not to state or local government agency payments. Some state and local government agencies may choose to participate in Same Day ACH processing.

► Will non-monetary ACH transactions be eligible for same day processing?

The following non-monetary ACH transactions will process same day if submitted within the processing windows:

  • Prenotifications for future credits are eligible in phase one, however, it is not likely a correction will be received back on the same day.
  • Remittance information using Cash Concentration or Disbursement (CCD) and Corporate Trade Exchange (CTX.)

► How do I sign up for Same Day ACH?

Contact your Treasury Management Relationship Manager.

► In phase one, what happens if a batch submitted for same day settlement includes debit and credit items?

In phase one, only credit items are eligible for same day settlement. While debits are not eligible for same day settlement, there is a possibility that debits will be submitted if sent in an ACH batch that is dated with a current or stale dated effective date. Any debit item(s) submitted in a batch that is dated with a current or stale dated effective day, will be processed and settled the next business day.

►If I send a Same Day ACH payment for processing, when will my account be debited?

 Your account will be debited the same day you originate the transaction.

►How important is the effective entry date?

With the introduction of Same Day ACH, the effective entry date in your batch file is critical. Assuming the file is submitted by the appropriate deadline, it is the effective entry date field that triggers same day settlement for eligible transactions. The current processing day in the effective entry date field, is interpreted as an intentional indication of the desire for same day settlement whether the effective entry date field contains the current processing date, or is invalid or stale.

►How can I ensure items not intended for same day settlement are processed properly?

If you have signed up for Same Day ACH, you should include a future date in the effective entry field to ensure future day settlement and send a separate ACH batch file.

►What will happen if I continue to send same day or stale dated files and I'm not signed up for Same Day ACH?

Stale dates will cause delays in normal ACH processing. Also, your file could be processed same day and you will be charged Same Day ACH fees.

►If I receive a Same Day ACH Credit, when will I see it in my account and how will I know it was a Same Day ACH?

Same Day ACH Credits received to your account will post by the end of the bank’s posting day. The transaction will post to your account with the same type of transaction description and details as the ACH Credits that currently post to your account today.

►Where can I obtain more information about Same Day ACH?

NACHA maintains a reference site for ACH users [Originators and Receivers] at https://www.nacha.org/content/same-dayachresource-center. You may wish to bookmark this site to view updates.


Examples of Effective Entry Date Processing Under Same Day ACH

With Same Day ACH, batches of Entries with invalid content or stale dates in the Effective Entry Date field will be settled at the next available settlement opportunity, which could be on the same day. This is important in handling ACH files that are late or that missed deadlines, such as payroll files, and for handling returns quickly. Same day returns will not be limited to the $25,000 per-transaction limit or the IAT exclusion that applies to forward transactions, nor will they be assessed the Same Day Entry fee.

►Next Day Settlement

A batch of Entries is submitted on Tuesday, November 1, 2016 with an Effective Entry Date of Wednesday, November 2 (i.e., with content “161102” in the Effective Entry Date field). This is valid information in the Effective Entry Date field, and the batch is settled at 7:30 a.m Central Tme on Wednesday, November 2. This represents no change from existing next day ACH processing, and there are no Same Day Entry fees.

►Same Day Settlement - Early Window

A batch of Entries is submitted on Tuesday, November 1, 2016 before 9:00 a.m. Central Time with an Effective Entry Date of Tuesday, November 1 (i.e., with content “161101” in the Effective Entry Date field). Under the Same Day ACH rule, this is now valid information in the Effective Entry Date field, and the batch is settled on Tuesday, November 1 at 12:00 p.m. CT (which is the settlement time that corresponds to the file submission time). These are Same Day Entries, and Same Day Entry fees apply.

►Same Day Settlement - Second Window

A batch of Entries is submitted on Tuesday, November 1, 2016 between 9:00 a.m. and 12:00 p.m. CT with an Effective Entry Date of Tuesday, November 1 (i.e., with content “161101” in the Effective Entry Date field). Under the Same Day ACH rule, this is now valid information in the Effective Entry Date field, and the batch is settled on Tuesday, November 1 at 4:00 p.m. CT (which is the settlement time that corresponds to the file submission time). These are Same Day Entries, and Same Day Entry fees apply.

►Same Day Intent - Next Day Window

A batch of Entries is submitted on Tuesday, November 1, 2016 after 12:00 p.m. CT with an Effective Entry Date of Tuesday, November 1 (i.e., with content “161101” in the Effective Entry Date field). Because the submission time is after ACH Operator’s last deadline for same day processing, this is invalid information in the Effective Entry Date field. Therefore the batch is settled at the next available settlement opportunity, which is Wednesday, November 2 at 7:30 a.m. CT. These are next day entries, and there are no Same Day Entry fees. (Note: Under this processing method, an ODFI could “hold” a file until after the ACH Operator’s last deadline for same day processing and ensure that the entries are not processed as Same Day Entries. This might be desirable in a situation in which the ODFI has not approved an Originator for same day processing, but the Originator uses the current date as the Effective Entry Date. In such a situation, the ODFI does not need to modify or edit the content of the Originator’s file.)

►Stale Date

A batch of Entries is submitted on Tuesday, November 1, 2016 before 9:00 a.m. CT with an Effective Entry Date of Monday, October 31 (i.e., with content “160926” in the Effective Entry Date field). Unfortunately, this is a late payroll file that was not submitted timely. The Effective Entry Date is invalid; therefore the batch will be settled at the next available settlement opportunity, which is at 12:00 p.m. CT on Tuesday, November 1. In this scenario, this late payroll file is settled 19.5 hours sooner than the similar situation above under the current Rules. (Note: Under this handling method, the ODFI does not need to change the content of the Effective Entry Date field in order for this sooner settlement to occur. If the rule had alternatively required the use of separate and distinct same day indicator, the ODFI would have to modify or edit the Originator’s file to insert the indicator in order to achieve this faster settlement.)



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