Removing Barriers Blog

Letter to NACHA on Recent ACH Changes
Posted October 07, 2015 by CUNA Advocacy

This week we sent a letter to NACHA – The Electronic Payments Association, to reiterate some credit union concerns about recent changes surrounding Same-Day Automated Clearing House (ACH) processing. We previously filed comments with both NACHA and the Board of Governors of the Federal Reserve (the Federal Reserve) about Same-Day ACH.

In the letter we reiterated that some credit unions have concerns about the implementation, ongoing costs, and other potential burdens resulting from changes requiring Same-Day capability for ACH transactions. We supportthe objective to provide a faster payments option on the ACH network, and we understand that there are costs and risk management issues associated with any evolution.

However, the letter states that we remain concerned about the mandate that all Receiving Depository Financial Institutions (RDFI) must have the ability to receive and post Same-Day ACH payments. Adding that, this requirement, without the option to opt-out, could be problematic, particularly for small credit unions.

Our letter also expressed appreciation to NACHA for considering our comments about requiring and interbank fee to help Receiving Depository Financial Institutions (RDFI). The letter states, “While we continue to think a higher fee may have been more appropriate, we appreciate NACHA’s attention to our comments.” Additionally, the letter urges NACHA to put any future changes to the amount of the interbank fee out for public and notice and comment, so that financial institutions have an opportunity to weigh in.

The letter also addressed potential compliance burdens with the timeline outlined for the three phases of implementation of Same-Day ACH. CUNA asked NACHA to continue to consider how these various phases will affect the operations of credit unions, who are already facing an unprecedented number of compliance hurdles. The letter states, “This is particularly true for our smaller credit unions, who have expressed the most concern about the impact of Same-Day ACH implementation.”

In closing, we urged NACHA to reconsider compliance deadlines for medium or smaller sized financial institutions to provide adequate time to prepare for this transition and to minimize compliance and cost burdens.

We plan to continue to engage with both NACHA and the Federal Reserve about the implementation of Same-Day ACH.