ACH

Preparing for Same Day ACH

The Federal Reserve Bank will require banks to process Same Day ACH transactions beginning in September. This is a 3-phase roll out over a 19-month period that began September 23, 2016. It’ll affect your institution and the timing of how you process each day.

PHASE 1 – September 23, 2016 (Completed)
Banks are required to receive and process Same Day ACH credits. These transactions must be posted with the rest of the transactions for that day. No specific time frame is given for when the transactions must be posted and available to customers. If you’re an on-line, real-time bank, the transactions will be reflected immediately upon processing the file; however, the transactions also need to be included in your final end of day update.

PHASE 2 – September 15, 2017
Banks will be required to receive and process Same Day ACH debits. These transactions must be posted with the rest of the transactions for that day. No specific time frame is given for when the transactions must be posted and available to customers. If you are an on-line, real-time bank, the transactions will be reflected immediately upon processing the file; however, the transactions also need to be included in your final end of day update.

PHASE 3 – March 16, 2018
Banks will be required to have the funds available to all customers from Same Day transactions by 5 p.m. local time. For ATM batch processing banks, this would be accomplished by processing the file and then sending a new positive balance file to your ATM/debit card vendor by 5 p.m.

If your bank is on-line and/or real-time for ATM/debit cards, you’ll need to process the ACH file by 5 p.m. local time, and the transactions will be reflected in the customer’s balance for Internet banking and ATM.

There are a few things that the bank should be doing in regards to Same Day ACH:

  • Become familiar with the cut-off times at the Fed Window for Same Day processing if you’re planning to originate Same Day ACH.
  • If your ACH files come in from a third party correspondent bank, you should find out when these files will be available to you to process. This will help you to establish your new end of day processing time frames and personnel requirements.
  • You should also see if your correspondent bank will be notifying you if there’s no Same Day ACH files for that afternoon rather then you checking for the files each afternoon. This could provide you with advanced notice and the ability to start your end of day processing earlier. 

IMPORTANT!! Please contact your MBS sales rep to discuss other options which may exist for handling the bank’s processing if you don’t want to have your staff wait for the afternoon Same Day ACH file to come in and then complete your end of day processing that afternoon or evening.

References
NACHA, the Electronic Payment Association
The Federal Reserve
For more information, please visit the Federal Reserve Bank Services