NACHA: Proposal to Implement Same Day
ACH Settlement
ABA Contact: Steve Kenneally
Published Proposal: https://www.nacha.org/news/nacha-releases-request-comment-same-dayach
Comments due: February 6, 2015
Disposition: Pending
Summary of the Proposals:
NACHA is requesting comment on a proposal to implement same day ACH settlement (SDA) by
adding two clearing windows to supplement the overnight batch process that is in use today.
These morning and afternoon clearing windows would allow entries to be cleared and settled on
the same day they are originated. While there is no mandate to originate these faster
transactions, NACHA’s proposal would require that all Receiving Depository Financial
Institutions (RDFIs) make upgrades to technology and procedures to accept these transactions.
Originating Depository Financial Institutions (ODFIs) would pass along an interbank
compensation fee of 8.2 cents for each transaction to the RDFIs to offset costs associated with
the mandated change.
NACHA’s economic analysis projects that SDA volume will grow from 37 million entries in
2016 to almost 1.4 billion in 2027. The forecast indicates that a large part of this volume will be
Business-to-Business transactions and Consumer-to-Business Transactions.
The proposal would implement SDA in three phases beginning with allowing credits to be
processed using two additional windows at 10 am and 3 pm Eastern Time. These would settle at
5 pm. Phase Two would allow debits and credits to be processed. Phase Three would introduce
a third settlement time at noon for those transactions included in the 10 am window. The
NACHA RFC outlines an implementation timeline where Phase One would be effective
September 16, 2016; Phase two on September 15, 2017; and Phase Three on March 16, 2018.
The proposal would make all ACH entries eligible for same day transactions with the exceptions
of International ACH Transactions (IATs) and those valued at more than $25,000.
Some key issues to address in ABA’s formal comment letter will include:
 Is the two window SDA concept sound?
 Is the proposal economically reasonable?
 Is the phased approach desirable?
 Are the implementation dates feasible?
 What are the fraud and security implications of SDA?
Comments are due on February 6, 2015. Please contact Steve Kenneally at skenneally@aba.com
for more information or if you are interested in participating in the comment process.