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CUNA sent a letter to the Federal Reserve last Tuesday in
regards to a proposal to adopt a rule from NACHA, the Electronic Payments
Association regarding Same Day ACH. We sent
the letter because the change to Same Day ACH will impact credit unions because
it would require all Receiving Depository Financial Institutions (RDFIs) to
accept same day transactions.
The proposed rule stems from a vote of NACHA’s membership in
May to approve Same Day ACH. The amendment
to the Operating Rules requiring Same Day processing of virtually any ACH
payment (for credits and debits). The existing ACH schedules and capabilities
would continue to apply to transactions unless they are designated as Same Day
Under these new NACHA rules, all RDFIs would be required to
receive Same Day ACH payments in order to provide certainty to Originators
desiring Same Day processing and settlement. The rule establishes the
methodology for a Same Day Entry fee as a mechanism for RDFIs to recover some
of their costs. The proposal will change the current optional FedACH SameDay
Service to conform with NACHA’s new rule. This includes requiring mandatory
participation by RDFIs and an interbank fee paid by the Originating Depository
Financial Institution (ODFI) to the RDFI for each Same Day ACH forward
transaction. The effective dates of the three implementation phases for the
NACHA rule are contingent on receiving written confirmation from the Federal
Reserve to support the rule.
CUNA states in its letter that we support efforts to meet the
goal of faster payments system with ubiquitous capabilities, and we understand
the public benefits provided by faster payments and availability of funds.
Further, the letter states that we also share NACHA and the Federal Reserve’s
goal of modernizing and improving the payments system. However, CUNA points out
that it does have some concerns regarding the requirement that all RDFIs have
the ability to receive and post same day payments. Implementation of these and
the ongoing costs will be burdensome to credit unions, specifically for smaller
credit unions with low Same Day ACH transaction volume.
CUNA's letter further notes that if implemented Same Day ACH
must account for the costs imposed on RDFIs. The proposed interbank fees are
necessary for RDFIs to make a dent in offsetting the initial implementation
costs and ongoing operational costs from Same Day ACH. CUNA will continue
to advocate that the Federal Reserve and NACHA must going forward evaluate
additional alternatives which could reduce costs associated with Same Day ACH
for small financial institutions.
For more information please contact Leah Dempsey.
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Credit Union National Association is the most influential financial services trade association and the only national association that advocates on behalf of all of America's credit unions. We work tirelessly to protect your best interests in Washington and all 50 states. We fuel your professional growth at every level and champion the credit union story at every turn.
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