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On October 8^th, 2024, Nacha began the Request for Comment (RFC) information gathering process for two new proposed rules, one involving adding a 4^th Same Day ACH window and another to accelerate next-day funds availability for ACH credits. In addition, Nacha also proposed two Request for Information (RFI) gathering requests for the ACH credit two-day timeframe and is encouraging more usage out of same-day returns. For anyone interested in commenting on one or both of these proposed rule changes along with the information gathering requests, RFCs and RFIs are both due by Friday, December 13^th, 2024. 

Request for Comments (RFC) – Nacha’s proposed rules:

#1 – Adding a Fourth Daily Same Day ACH (SDA) Processing Window

Currently, Nacha has the following funds availability times following the transmission and settlement timeframes on the ACH Network:

According to Nacha, establishing a fourth Same Day ACH (SDA) processing window would be “aligned with the close of business in the Pacific time zone”. As noted, the transmission times are in the Eastern time zone other than the funds availabilities which are local time. Adding the fourth SDA window would make the processing window schedule look like the following:

Note: 10:00pm ET settlement occurs Sunday through Thursday. For example, something sent late Friday night would settle on Sunday night.

Nacha lists the following as benefits of adding the 4^th SDA window:

• Greater opportunity for Originating (ODFIs) and Originators to initiate SDA payments.
• Beneficial timeframe to Western time zones, particularly the Pacific time zone.
• Could increase use cases of SDA while encouraging more returns using SDA windows.

However, Nacha lists the following as impacts of adding the 4^th SDA window:

• All Receiving Depository Financial Institutions (RDFIs) would have to implement the receipt of SDA files in the new window and meet funds availability requirements.
• The Friday night to Sunday night settlement time period for the 4^th window.
• RDFI may be in a net-debit settlement position at settlement time and may need additional funding to cover.
• ACH debits will be sent through this 4^th window, and business receivers in particular may need to monitor their account during this SDA timeframe. 

#2 – Accelerate Funds Availability for Certain ACH Credits

Per ACH Rules Subsection 3.3.1.1, RDFIs are required to make funds available for non-Same Day ACH credits by 9 AM local time on the settlement day if the credit is received by the RDFI by 5 PM local time on the day before the settlement. Yet with ACH Operator file delivery schedules, they deliver multiple files daily after 5 PM. The proposal would effectively remove the “5 PM local time receipt condition” as seen by the elimination of language in the proposed rule change:

According to Nacha, the removal of the 5 PM receipt requirement would provide the following anticipated benefits:

• Accelerate funds availability for ACH credits received after 5 PM that are currently not made available by 9 AM local time on its settlement date.
• Increases of various use cases for various ACH credit types (payroll, benefits, cashouts, refunds, invoices, etc.).

Nacha also indicates possible impact, particularly for institutions who weren’t already making funds available at 9 AM local time for files received after 5 PM for payments with the next day’s settlement:

• Change of internal process and procedures to make ACH credit funds available by 9 AM local time for ACH credits received after 5 PM

Request for Information (RFI) – Obtaining Industry Perspectives:

#1 – Two-Day ACH Credits

For ACH credits, Nacha Rules allow them to have an effective date of the current banking day for Same Day ACH purposes and one to two banking days in the future. Meanwhile, ACH debits may have an effective date of the current banking day for Same Day ACH purposes and one banking day in the future.  According to Nacha, 2023 data shows 80% was estimated of all ACH payments settle in one day or less. In addition, Same Day ACH volumes continue to increase. 

Nacha is requesting information on whether ACH Rules could be changed to require credits to settle just one banking day in the future when transmitted to align with the timeframe of ACH debits. Benefits and impacts are sought by Nacha if this were considered as a Rule change. 

#2 – Encouraging Same Day ACH Returns

Since Same Day ACH began during September 2016, same-day processing windows have existed to process ACH returns. Yet, there appears to be low usage of these same-day windows for returns despite the expressed benefits posed to both ODFIs and RDFIs (as well as Originators and Receivers). 

Nacha is requesting information from respondents as to why RDFIs do not utilize same-day windows for return processing and what could the industry do to promote and encourage usage of those SDA windows for faster ACH return processing. 

View the proposed modifications and supporting documentation here. You can also register for our FREE, members-only Special Industry Update webinar October 22^nd at 10 AM CT/11 AM ET to dive deeper into the Requests for Comment and Information. Your input is key in helping shape EPCOR’s responses!