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The new Same Day ACH window is fast approaching: Will your credit union be ready?

By Steve Jones, AAP, VP, Product Manager

Effective March 19, 2021, the new Same Day ACH rule creates a new processing window, enabling Originating Depository Financial Institutions (ODFIs) to originate Same Day ACH (SDA) transactions for an additional two hours each banking day, providing greater access for all ODFIs and their members. The timing of this new processing window is intended to balance expanding access to Same Day ACH with the desire to minimize impacts on financial institutions’ end-of-day operations and their reopening of the next business day.

Reviewing the details

With the new window, SDA files can be submitted to the ACH Operators until 4:45 p.m. Eastern Time (ET), which is 1:45 p.m. Pacific Time (PT). Under the rule change, the Fed will keep its National Settlement service open until 6:30 p.m. ET, one hour later than its current closing time. The Fedwire Funds Service will stay open 30 minutes longer until 7:00 p.m. As a result, the latest daily deadline for Same Day ACH will occur at 4:45 p.m. ET, two hours later than the current cut-off.

This timing provides ODFIs operating in PT with a file submission schedule into the early afternoon. Receiving Depository Financial Institutions (RDFIs) would receive files of SDA transactions by 5:30 p.m. ET/2:30 p.m. PT, and interbank settlement would occur at 6:00 p.m. ET/3:00 p.m. PT. An RDFI would make funds available for SDA credits in this new SDA processing window no later than the end of its processing day. The chart below summarizes the details.

Processing Window

+ACH Operator Deadline

*File Availability from ACH Operator

Settlement

RDFI Funds Availability

1st SDA File

10:30 a.m. ET

Noon ET

1:00 p.m. ET

1:30 p.m. Local Time

2nd SDA File

2:45 p.m. ET

4:00 p.m. ET

5:00 p.m. ET

5:00 p.m. Local Time

3rd SDA File

4:45 p.m. ET

5:30 p.m. ET

6:00 p.m. ET

End of Processing Day

*Corporate One makes files available as soon as possible upon receipt from the ACH Operator
+Corporate One Origination cut off is 30 minutes prior to ACH Operator deadline


All credits and debits, and all returns (and Notifications of Change), would be eligible to be processed in the new SDA window except for international ACH transactions (IATs), automated enrollments (ENRs), and forward transactions over the per-transaction dollar limit.

The existing “returns-only” window provided by the ACH Operators will be absorbed into the new SDA processing window. This will enable RDFIs to send returns later into the day, up to 4:45 p.m. ET/1:45 p.m. PT. This also provides greater ability for RDFIs to make use of SDA processing for returns, which would get settled 14.5 hours earlier than next-day returns. See the chart below for a summary of the returns processing time frames.

Returns Processing

RDFI Submission Deadline

Settlement

Existing “returns only” window

4:00 p.m. ET
1:00 p.m. PT

5:00/5:30 p.m. ET
2:00/2:30 p.m. PT

Returns in new SDA window

4:45 p.m. ET
1:45 p.m. PT

6:00 p.m. ET
3:00 p.m. PT

Considerations for your credit union

The later window for same-day settlement will affect a wide range of transactions. The ACH network handles payroll and business payments, as well as business-to-business and peer-to-peer transfers. Also, many other payment systems use the ACH rails and often depend on the ACH same-day capability. During the new Rule’s “Request for Comment” period, several organizations identified impacts to end-of-day processing activities, including a shift in timing for non-ACH services, such as wire transfer. From an enterprise-wide-perspective, it’s important for credit unions to evaluate the processes beyond ACH that may change as a result of implementing the new window.

For example, since the Fedwire Funds Service will remain open longer, will your credit union change the cut-off time for wires? Will your cash-management processes be impacted? These are just a couple of considerations to keep in mind, including the following:

For RDFIs:

  • Processes and procedures. How will the later file and end-of-day processes impact current operations? What updates need to be made?
  • Funds availability. Will there need to be changes in order to meet the end-of-processing day requirement?
  • Education for appropriate staff. Any new procedure/process changes should also include front line and call-center employees.
  • Education opportunities for:
    • Originators using Same Day ACH services. Can your members benefit from this new window?
    • Treasure/Cash-management staff. Include these employees in information about the rule change and any new processes associated with the new window.

The new Same Day ACH window represents continued growth and opportunity for credit unions and their members. For example, a member survey in 2017 by a regional payments association that represents financial institutions in the western U.S. found that 31% of its ODFI respondents were originating SDA transactions but that an additional 35% (for a total of 66%) would consider doing so with expanded hours. The potential for this kind of growth means it’s important to make sure you are prepared for the new window by starting early to evaluate and identify impacted processes so that the transition is smooth and successful not only for your credit union but also for your members.