Introduction. Page 1. Introduction

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1 Introduction Introduction The combined impact of customer demand, expanding technological capabilities, evolving regulatory expectations of reduced risk exposure, and other market forces are driving financial institutions towards faster funds availability and shorter cycle times for all payment transactions. Advances like mobile commerce, Internet banking, and cross-channel integration are creating a growing demand for more flexible processing across all payment channels. The ACH Network is not immune to these forces and is considering how best to embrace them with enhancements to enable FIs to take advantage of new technology and respond effectively in the marketplace. The current ACH settlement schedules (next-day or, for some credits, 2-day value-dated) have been in place with minimal changes for over 35 years. Various financial institutions and industry observers are now identifying a number of benefits that can accrue from more frequent and flexible ACH processing and settlement windows including: Opportunities for new value added services and product differentiation Potential sources of new fee income Enhanced customer service and retention Improved error correction capabilities Increased contingency and business continuity capabilities Load balancing and other operational efficiencies Cost avoidance (e.g., replacing teller line cash and check deposits with electronic deposits) The utilization of more frequent and more flexible processing and settlement windows would also enable financial institutions to improve their own risk profiles, as well as that of the ACH Network. By reducing the duration of clearing and settlement exposure for forward and return entries, financial institutions can reduce counterparty settlement risk and risk-based capital adequacy requirements, and more effectively mitigate systemic and credit risk. Additional processing and settlement windows would also allow financial institutions to better manage operational risk by enabling more timely error correction and recovery from late or disrupted file processing. Survey The purpose of this survey is to gain a better understanding of industry capabilities and capacity as part of the planning process around the concept of developing more frequent and flexible processing and settlement schedules for the ACH Network. It is also intended to develop a better understanding of the potential benefits and costs involved in moving towards a more flexible environment. This survey focuses on four specific scenarios as a means to examine the potential impact of more frequent and flexible processing and settlement schedules on ODFIs, RDFIs and their customers. Please consider each scenario and respond to the corresponding questions. Within each scenario we also ask questions regarding various processing windows and time frames. In addition to asking questions regarding a morning and an afternoon window, we have included open ended questions to help us to better understand your ability to process at other times during the day. The survey concludes with summary and demographic questions. Questions are asked from both the ODFI and the RDFI perspectives. Even if you are only originating transactions for your own accounts, such as bill payments initiated via your website for your loan and card accounts, you should still respond to the ODFI section of the survey. When responding as an RDFI, consider transactions received for external business and consumer accountholders, as well as transactions received for loan, card and other accounts at your institution, as applicable. Your participation in this survey is appreciated. To access and complete this survey online please visit: click here Page 1

2 ODFI - Scenario #1 Intro Scenario #1 Consumer-Initiated P2P Remittance and Bill Payments via Web or Mobile Channels to an FI-supported Online Banking Service (Consumer Credits) Alternative 1: A consumer accountholder wants to pay bills, some of which may be due today, using his financial institution s online banking service, either over his lunch break or when he gets home from work. Alternative 2: A consumer accountholder wants to use her financial institution s online banking service to send a remittance payment to her child at college, either during the day or when she gets home from work, and she wants her child to have access to those funds as soon as possible, preferably today, or early tomorrow morning. 1. As an ODFI, answer the following questions assuming that additional ACH processing and settlement windows are available for ACH credits that would enable your consumer customers to initiate faster P2P remittance or bill payments via your online banking service. We are not/have no plans to be an ODFI for these types of transactions. Page 2

3 ODFI - Scenario #1 2. If a file transmission deadline of 8:00 a.m. Eastern Time were available (with RDFI file availability by 10:00 a.m. and settlement at 11:00 a.m.): How much value would this window provide to you and your consumer customers who want to make faster P2P remittance or bill payments via your online banking service? High Medium Low 3. If a file transmission deadline of 2:00 p.m. Eastern Time were available (with RDFI file availability by 4:00 p.m. and settlement at 5:00 p.m.): How much value would this window provide to you and your consumer customers who want to make faster P2P remittance or bill payments via your online banking service? High Medium Low 4. What is the earliest deadline (in Eastern Time) for transmission to the ACH Operator that would still provide significant additional value to you and your consumer customers who want to make faster P2P remittance or bill payments via your online banking service, assuming RDFI file availability two hours later and settlement one hour after that? Page 3

4 5. Rate the following benefits (High/Medium/Low) or n/a (not applicable) as you would expect to realize them as an ODFI of consumer credits that allow your customers to initiate faster P2P remittance or bill payments via your online banking service, utilizing additional processing and settlement windows. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction Improved error correction Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) 6. Rate the estimated level of internal development you would need in order to enable your customers to initiate faster P2P remittance or bill payments via your online banking service, utilizing additional processing and settlement windows: Minimal, our existing technology and systems can handle this with little change Medium, we would need to make a fair amount of change to our existing systems High, we would need to make a significant investment in our systems 7. Please provide any other general comments you have as an ODFI for consumer customers who want to initiate faster P2P remittance or bill payments via your online banking service, utilizing additional processing and settlement windows. Page 4

5 RDFI - Scenario #1 Scenario #1 Consumer-Initiated P2P Remittance and Bill Payments via Web or Mobile Channels to an FI-supported Online Banking Service (Consumer Credits) Alternative 1: A consumer accountholder wants to pay bills, some of which may be due today, using his financial institution s online banking service, either over his lunch break or when he gets home from work. Alternative 2: A consumer accountholder wants to use her financial institution s online banking service to send a remittance payment to her child at college, either during the day or when she gets home from work, and she wants her child to have access to those funds as soon as possible, preferably today, or early tomorrow morning. As an RDFI and/or a Receiver for your own institution (FI as a biller), answer the following questions assuming that additional processing and settlement windows are available for ACH credits that would enable your customers to receive faster payments. Page 5

6 RDFI - Scenario #1 8. If a new window for the delivery of ACH credits were created, what is the latest pickup time, in Eastern Time, that will still allow you to make funds available to your consumer accountholders the same day on the day of posting? 9. If a new window for the delivery of ACH credits were created, what is the latest pickup time that will still allow you to make funds available to your business (biller) accountholders the same day in Eastern Time on the day of posting? 10. If a new window for the delivery of ACH credits were created, when will you be able to, in Eastern Time on the day of posting, provide the customer account data to billers for posting? 11. If a new window for the delivery of ACH credits were created, what is the latest pickup time, in Eastern Time, that will still allow you to make funds available to internal systems (e.g., mortgage loan, installment loan, credit card) at your institution the same day? 12. If a new window for the delivery of ACH credits were created, when, in Eastern Time, would you be able to provide the customer account data to internal systems for posting? Page 6

7 13. As an RDFI of faster P2P remittance and bill payments, rate the benefit to your institution (High/Medium/Low) or n/a (not applicable) as you would expect to realize them of a new window that would require you to pick-up files by 10:00 a.m. Eastern Time (with settlement at 11:00 a.m.), and make funds available to customers the same day. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction Improved error correction Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) 14. Please list any additional benefits not mentioned above you would expect to realize as an RDFI of consumer credits that allow your customers to initiate faster P2P remittance or bill payments via your online banking service, utilizing additional processing and settlement windows. 15. As an RDFI of faster P2P remittance and bill payments, rate the benefit to your institution (High/Medium/Low) or n/a (not applicable) as you would expect to realize them of a new window that would require you to pick-up files by 4:00 p.m. Eastern Time (with settlement at 5:00 p.m.), and make funds available to customers the same day. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction Improved error correction Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) Page 7

8 16. Rate the estimated level of internal development you would need in order to allow you to make funds available to your customers on a same day basis for P2P remittance and bill payments received, utilizing additional processing and settlement windows: Minimal, our existing technology and systems can handle this with little change Medium, we would need to make a fair amount of change to our existing systems High, we would need to make a significant investment in our systems 17. Please provide any other general comments you have as an RDFI of faster P2P remittance and bill payments received for your customers, utilizing additional processing and settlement windows. Page 8

9 ODFI - Scenario #2 Scenario #2 Emergency and Expedited Direct Deposit of Payroll Services A payroll manager has an emergency involving standard payroll (e.g., missed file delivery deadline), or wishes to pay hourly workers for wages earned through Thursday, and needs to initiate a payroll file on Friday payday and employees must be able to access payroll funds at some point that day. The payroll manager is able to initiate the payroll file on payday, either 1) directly through his FI, or 2) through a thirdparty payroll service. 18. As an ODFI, answer the following questions assuming that additional processing and settlement windows are available for ACH credits that would allow your business customers (employers and payroll processors) to pay employees on payday via Direct Deposit in emergency situations, or to expand their use of Direct Deposit to pay hourly employees. We are not/have no plans to be an ODFI for these types of transactions. Page 9

10 19. If a file transmission deadline on Friday of 8:00 a.m. Eastern Time were available (with RDFI file availability by 10:00 a.m. and settlement at 11:00 a.m.) how much value would this window provide to you and your business customers that want to more fully utilize Direct Deposit to pay employees? High Medium Low 20. If a file transmission deadline on Friday of 2:00 p.m. Eastern Time were available (with RDFI file availability by 4:00 p.m. and settlement at 5:00 p.m.) how much value would this window provide to you and your business customers that want to more fully utilize Direct Deposit to pay employees? High Medium Low 21. What is the earliest deadline, in Eastern Time, on Friday for transmission to the ACH Operator that would still provide significant additional value to you and your business customers that want to more fully utilize Direct Deposit to pay employees, assuming RDFI file availability two hours later and settlement one hour after that? 22. Rate the following benefits (High/Medium/Low) or n/a (not applicable) as you would expect to realize them as an ODFI for business customers that need to pay employees on payday via Direct Deposit in emergency situations, or to expand their use of Direct Deposit to pay hourly employees. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction Improved error correction Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) Page 10

11 23. Rate the estimated level of internal development you would need in order enable your business customers to pay employees on payday via Direct Deposit in emergency situations, or to expand their use of Direct Deposit to pay hourly employees, utilizing additional processing and settlement windows: Minimal, our existing technology and systems can handle this with little change Medium, we would need to make a fair amount of change to our existing systems High, we would need to make a significant investment in our systems 24. Please provide any other general comments you have as an ODFI for business customers that need to pay employees on payday via Direct Deposit in emergency situations, or to expand their use of Direct Deposit to pay hourly employees, utilizing additional processing and settlement windows. Page 11

12 RDFI - Scenario #2 Scenario #2 Emergency and Expedited Direct Deposit of Payroll Services A payroll manager has an emergency involving standard payroll (e.g., missed file delivery deadline), or wishes to pay hourly workers for wages earned through Thursday, and needs to initiate a payroll file on Friday payday and employees must be able to access payroll funds at some point that day. The payroll manager is able to initiate the payroll file on payday, either 1) directly through his FI, or 2) through a thirdparty payroll service. As an RDFI, answer the following questions assuming that additional processing and settlement windows are available for ACH credits that would enable your consumer accountholders to be paid on payday via Direct Deposit in emergency situations or paid via Direct Deposit if they are hourly employees who are not being paid by Direct Deposit currently. 25. If you were required to pick-up files by 10:00 a.m. Eastern Time on Friday (with settlement at 11:00 a.m.), when would you be able to make funds available to your consumer accountholders who are paid via Direct Deposit? (Eastern Time) the day of posting Other: 26. If you were required to pick-up files by 4:00 p.m. Eastern Time on Friday (with settlement at 5:00 p.m.), when would you be able to make funds available to your consumer accountholders who are paid via Direct Deposit? (Eastern Time) the day of posting Other: 27. If a new window for the delivery of ACH credits where created, what is the latest pickup time that would still allow you to make funds available the same day to your consumer accountholders who are paid via Direct Deposit? (Eastern Time) the day of posting Other: Page 12

13 28. Rate the following benefits (High/Medium/Low) or n/a (not applicable) as you would expect to realize them as an RDFI making funds available to consumer accountholders that are received via Direct Deposit in emergency situations, or for customers who are hourly workers and may not be enrolled in Direct Deposit currently, utilizing additional processing and settlement windows. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction Improved error correction Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) 29. Rate the estimated level of internal development you would need in order to utilize additional processing and settlement windows to enable your consumer accountholders to be paid on payday via Direct Deposit in emergency situations or paid via Direct Deposit if they are hourly employees who may not be enrolled in Direct Deposit currently: Minimal, our existing technology and systems can handle this with little change Medium, we would need to make a fair amount of change to our existing systems High, we would need to make a significant investment in our systems 30. Please provide any other general comments you have as an RDFI regarding the implementation of additional processing and settlement windows to enable consumer accountholders at your institution to be paid via Direct Deposit in emergency situations, or who are hourly workers and may not be enrolled in Direct Deposit currently. Page 13

14 ODFI - Scenario #3 Scenario #3 Consumer Debits (Biller Direct or ODFI as Originator) A financial institution supports business (biller) customers and/or collections for its own credit card and loan products, with lockbox receivables collected in the morning, and WEB and TEL transactions processed throughout the day and into the evening. Its internal and external business (biller) clients would like faster collection of funds and faster information on returns. 31. As an ODFI and/or Originator for your own institution (FI as biller), answer the following questions assuming that additional ACH processing and settlement windows are available for consumer ACH debits that could enable you to more rapidly collect funds and receive returns. We are not/have no plans to be an ODFI for these types of transactions. Page 14

15 32. If a file transmission deadline of 8:00 a.m. Eastern Time were available (with RDFI file availability by 10:00 a.m. and settlement at 11:00 a.m.) how much value would this window provide to you and your business (biller) customers? High Medium Low 33. If a file transmission deadline of 2:00 p.m. Eastern Time were available (with RDFI file availability by 4:00 p.m. and settlement at 5:00 p.m.) how much value would this window provide to you and your business (biller) customers? High Medium Low 34. What is the earliest deadline, in Eastern Time, for transmission to the ACH Operator that would still provide significant additional value to you and your business (biller) customers, assuming RDFI file availability two hours later and settlement one hour after that? 35. Rate the following benefits (High/Medium/Low) or n/a (not applicable) as you would expect to realize them with more frequent and flexible processing and settlement windows that allow you, as an ODFI of consumer debits, to provide faster collection of funds and receipt of returns for your business (biller) customers and for bill payments from your institution s consumer customers. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction (e.g., ability to receive returns at least 1 day faster) Improved error correction Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) Page 15

16 36. Rate the estimated level of internal development you would need in order to support the faster collection of consumer bill payments for your business (biller) customers or your own institution, including the provision of related information for returns: Minimal, our existing technology and systems can handle this with little change Medium, we would need to make a fair amount of change to our existing systems High, we would need to make a significant investment in our systems to take advantage of this new capability 37. Depending upon the capabilities of RDFIs, additional processing and settlement windows could enable faster returns, ideally on the same day as the original item. Rate the estimated level of internal development you would need to receive and process faster returns and provide the related information to your business (biller) customers: Minimal, our existing technology and systems can handle this with little or no change Medium, we would need to make a fair amount of change to our existing systems High, we would need to make a significant investment in our systems to take advantage of this new capability 38. Please provide any other general comments you have as an ODFI of consumer debits regarding the ability to more rapidly collect bill payments for your business (biller) customers and for bill payments from your institution s consumer customers. Page 16

17 RDFI - Scenario #3 Scenario #3 Consumer Debits (Biller Direct or ODFI as Originator) A financial institution supports business (biller) customers and/or collections for its own credit card and loan products, with lockbox receivables collected in the morning, and WEB and TEL transactions processed throughout the day and into the evening. Its internal and external business (biller) clients would like faster collection of funds and faster information on returns. As an RDFI and/or Receiver for your own institution, answer the following questions assuming that additional processing and settlement windows are available for ACH debits that could enable your consumer customers to pay their bills more rapidly to avoid late payments and provide you faster re-credit for returns. 39. If you were required to pick-up files by 10:00 a.m. Eastern Time (with settlement at 11:00 a.m.), what is the earliest return file deadline you could meet? (Eastern Time) same day (Eastern Time) next day Other 40. If you were required to pick-up files by 4:00 p.m. Eastern Time (with settlement at 5:00 p.m.), what is the earliest return file deadline you could meet, assuming that you decided to use faster returns? (Eastern Time) same day (Eastern Time) next day Other 41. What is the latest pick-up time that will still allow you to post debits to your accountholders the same day? (Eastern Time) same day (Eastern Time) next day Other 42. What is the latest pick-up time for inbound files that will allow you to process and return items the same day? (Eastern Time) same day (Eastern Time) next day Other Page 17

18 43. Assuming that you are able to take advantage of faster returns, which items would you likely return the same day? Administrative Returns only (e.g., Account Closed, Invalid Account Number Structure, Unable to Locate Account) All Returns Other (please specify) 44. As an RDFI, rate the benefit to your institution of additional processing and settlement windows that would enable you to return and settle for transactions the same day that you receive the original debit, reducing your overall exposure. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction (e.g., faster re-credit of funds) Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) 45. Rate the estimated level of internal development you would need in order to process and return items the same day that you receive the original transaction: Minimal, our existing technology and systems can handle this with little or no change Medium, we would need to make a fair amount of change to our existing systems High, we would need to make a significant investment in our systems 46. Please provide any other general comments you have as an RDFI regarding additional processing and settlement windows that would enable your consumer customers to pay their bills more rapidly and avoid late payments, and provide you faster re-credit for returns. Page 18

19 ODFI - Scenario #4 Scenario #4 "Super" Prenotes A financial institution supports business customers and/or originates for its own products. Both the financial institution and its Originators wish to validate Receiver bank account information before originating ACH Network transactions. Current prenotes are often considered unsatisfactory for this purpose due to the lack of positive acknowledgement and the delay required between an initial prenote and live transactions. A new super prenote could potentially solve that problem by requiring the RDFI in the NACHA Operating Rules to provide a positive or negative acknowledgement within specified timeframes. At a minimum, the acknowledgement would validate that the R/T and account number combination matched an active account at the RDFI and was postable. Given the improved level of service to the Originator, this fundamentally new service could potentially be offered as a value-added service with new revenue streams for both ODFIs and RDFIs. 47. As an ODFI and/or Originator for your own institution, answer the following questions assuming that additional processing and settlement windows are available for super prenotes, and a rule requiring RDFI acknowledgment within specified timeframes were implemented that could enable you or your business customers to more rapidly validate MICR line information. We are not/have no plans to be an ODFI for these types of transactions. Page 19

20 48. Rate the value (High/Medium/Low) or n/a (not applicable) to you and your business customers of the specified required timeframes for RDFI acknowledgment of a super prenote for the provided processing windows. RDFI Acknowledgement Required the Same Day RDFI Acknowledgement Required within 1 Day RDFI Acknowledgement Required within 2 days 8:00 a.m. Eastern Time ODFI Transmission Deadline 10:00 a.m. Eastern Time ODFI Transmission Deadline 2:00 p.m. Eastern Time ODFI Transmission Deadline 4:00 p.m. Eastern Time ODFI Transmission Deadline What is the latest response timeframe for the new super prenotes that would still provide significant additional value to you and your business customers to validate MICR line information? RDFI Acknowledgment Required the same day RDFI Acknowledgment Required the next day RDFI Acknowledgment Required within 2 Days Page 20

21 50. Rate the following benefits (High/Medium/Low) or n/a (not applicable) as you would expect to realize them as an ODFI of super prenotes that would more rapidly validate MICR information for you and your business customers. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction Improved error correction Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) 51. Rate the estimated level of internal development you would need to take advantage of the new super prenote transaction with additional processing windows to more rapidly validate MICR line information for you and your business customers: Minimal, our existing technology and systems can handle this with little change Medium, we would need to make a fair amount of change to our existing systems High, we would need to make a significant investment in our systems 52. Please provide any other general comments you have as an ODFI regarding the ability to more rapidly validate MICR information for you and your customers with additional processing windows and an appropriate Rules structure. Page 21

22 RDFI - Scenario #4 53. If you were required to pick-up super prenote files by 10:00 a.m. Eastern Time, what is the earliest time you could originate acknowledgement transactions? (Eastern Time) Acknowledgment the same day (Eastern Time) Acknowledgment the next Day (Eastern Time) Acknowledgment within 2 Days 54. If you were required to pick-up super prenote files by 4:00 p.m. Eastern Time, what is the earliest time you could originate acknowledgement transactions? (Eastern Time) Acknowledgment the same day (Eastern Time) Acknowledgment the next Day (Eastern Time) Acknowledgment within 2 Days 55. As an RDFI, rate the potential benefits (High/Medium/Low) or n/a (not applicable) that you would expect to realize with the introduction of a new super prenote to enable you to offer a service of more rapidly validating MICR line information for transactions received on behalf of your customers. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction Improved error correction (i.e., reduced returns) Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) Page 22

23 56. Rate the estimated level of internal development you would need in order to support the new super prenote transaction with additional processing windows to more rapidly validate MICR line information for transactions received on behalf of your customers: Minimal, our existing technology and systems can handle this with little change Medium, we would need to make a fair amount of change to our existing systems High, we would need to make a significant investment in our systems 57. Please provide any other general comments you have as an RDFI regarding the ability to more rapidly validate MICR line information for transactions received on behalf of your customers with additional processing windows and an appropriate Rules structure. Page 23

24 Summary Questions Summary Questions This survey provided four scenarios as a way for you to evaluate the potential benefits of, and the level of development needed to support, more frequent and flexible processing and settlement windows. These four scenarios are representative and are by no means exhaustive. There may be other applications that you can think of that would also offer potential value to your institution. For the purpose of the following summary questions, consider holistically the potential benefits that more frequent and flexible processing windows could provide your institution and its customers today and in the next few years. 58. As an ODFI and/or Originator for your own institution, rate the total potential benefits (High/Medium/Low) or n/a (not applicable) for all transactions that you would expect to realize as a result of implementing more frequent and flexible ACH Network processing and settlement windows. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction/reduced regulatory burden Improved error correction Improved contingency processing (e.g., late files received from customers or missed Operator deadlines, system problems, disaster recovery) Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) Page 24

25 59. As an RDFI and/or Receiver for your own institution, rate the potential benefits (High/Medium/Low) or n/a (not applicable) that you would expect to realize as a result of implementing more frequent and flexible ACH Network processing and settlement windows. Value-added services/product differentiation High Medium Low N/A Fee income Customer service/retention Risk reduction/reduced regulatory burden Improved error correction Improved contingency processing (e.g., file accessibility, system problems, disaster recovery) Load balancing and other operational efficiencies Cost avoidance Other (please specify and rate) 60. Do you currently plan to make any significant changes to the following systems? This includes changes for regulatory compliance, system upgrades, or system efficiency, among others. Yes within the next 12 Yes within the next Yes within the next Discussing changes No, we have no months three years five years but no firm plans changes planned Core deposits/dda Return Items Online banking ACH Check Processing 61. Please provide any other general comments you have regarding implementing more frequent and flexible ACH Network processing and settlement windows. Page 25

26 Demographic Questions 62. Indicate your institution type: Natural Person Credit Union Community Bank Commercial Bank Savings institution Corporate Credit Union Core Processor Other (please describe) 63. Indicate your institution size (assets): $500 million and under $500+ million to $1 billion $1+ billion to $5 billion $5+ billion to $25 billion $25+ billion to $100 billion More than $100 billion 64. Indicate your ACH processing category: ODFI Credits only ODFI Debits only ODFI both Debits and Credits RDFI only (including initiated returns) Don t know Page 26

27 65. How do you pick up received ACH files and initiate returns? (Check all that apply) In-house directly from/to ACH Operator(s) Through a Processor Through a Correspondent / Corporate Credit Union / Bankers Bank Don t know Other (please describe) 66. How many times daily are your received ACH files picked up from the ACH Operators for processing? Once daily Twice daily Three or more times daily Don t know Varies based on (please describe) 67. How do you perform primary posting and settlement operations? In-house Through a Processor Through a Correspondent / Corporate Credit Union / Bankers Bank Don t know Other (please describe) Page 27

28 68. Indicate your core transaction processing capabilities: Online real time processing Batch processing with intraday posting of debits only note intraday can be via memo post, shadow balance file, or any other method that allows intraday updating of balances for inquiry and transaction processing purposes Batch processing with intraday posting of credits only Batch processing with intraday posting of both debits and credits Don t know Other (please describe) 69. Which ACH Operator do you currently use? Federal Reserve Bank TCH/EPN Both Don t know Page 28

29 70. Which association invited you to participate in this survey? (Check all that apply) Alabama ACH Association EastPay, Inc. EPCOR GACHA MACHA The Mid-Atlantic Payments Association NEACH SHAZAM, Inc. South Carolina ACH Association Southern Financial Exchange SWACHA The Electronic Payments Resource Tennessee ACH Association The Clearing House Payments Association The Payments Authority, Inc. Upper Midwest ACH Association (UMACHA) Viewpointe CS & AS WACHA The Premier Payments Resource Don t know NACHA (we are a NACHA Direct FI Member) Page 29

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