Removing Barriers Blog

CUNA Comments to the Federal Reserve on NACHA's Same Day ACH Proposal
Posted June 30,2015 by CUNA Advocacy

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 ACH.   

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.