Same Day ACH: What Does It Mean to Your Financial Institution?

Transcription

1 Same Day ACH: What Does It Mean to Your Financial Institution? Presented by WACHA Pre- Conference PAR/WACHA-The Premier Payments Resource Panelists: Laura Parsons FIS Wendy Stanford Bankers Bank Stacy Pritzel UFS Mike Reichert Lending Tools 1

2 Disclaimer WACHA, through its Direct Membership in NACHA, is a specially recognized and licensed provider of ACH education, publications and support. Regional Payments Associations are directly engaged in the NACHA rulemaking process and Accredited ACH Professional (AAP) program. NACHA owns the copyright for the NACHA Operating Rules & Guidelines. The Accredited ACH Professional (AAP) is a service mark of NACHA. This material is derived from collaborative work product developed by NACHA The Electronic Payments Association and its member Regional Payments Associations, and is not intended to provide any warranties or legal advice, and is intended for educational purposes only. This material is not intended to provide any warranties or legal advice, and is intended for educational purposes only. This document could include technical inaccuracies or typographical errors and individual users are responsible for verifying any information contained herein. No part of this material may be used without the prior written permission of WACHA/PAR 2015 PAR/WACHA All rights reserved 2

3 Eligible Transactions Individual Entries of $25,000 and under Over $25,000 will settle the next day All Standard Entry Class (SEC) codes except for International ACH Transactions (IATs) All Non-Monetary/Zero-Dollar transactions will be eligible for Same Day ACH immediately in Phase I Exception: Automated Enrollment Entries (ENRs) Prenotes for future debit Entries (Phase 1 only) 3

4 A Phased Approach to New ACH Network Functionality Functionality Phase 1 Sept. 23, 2016 Phase 2 Sept. 15, 2017 Phase 3 March 16, 2018 Transaction Eligibility ($25,000 limit; IAT not eligible) Credits only Credits and debits Credits and debits New Same Day ACH Processing Deadlines 10:30 AM ET and 2:45 PM ET 10:30 AM ET and 2:45 PM ET 10:30 AM ET and 2:45 PM ET New Settlement Time(s) 1:00 PM ET and 5:00 PM ET 1:00 PM ET and 5:00 PM ET 1:00 PM ET and 5:00 PM ET ACH Credit Funds Availability End of RDFI s processing day End of RDFI s processing day 5:00 PM RDFI local time Times shown represent the approximate times for an ODFI s deadlines to transmit same-day ACH transactions to an ACH Operator. 4

5 Phase I implementation date September 23, 2016 ACH credits become eligible Phase I Settlement for same day credits will occur at 1:00pm and 5:00 pm ET RDFIs are required to make funds available (not available for withdrawal) from Same Day ACH credits by the end of their processing day 5

6 Same Day Entry Fee Designed to mitigate operating and investment costs for RDFIs who will all be required to participate in Same Day ACH Approved fee is set at 5.2 cents per Same Day transaction to be paid by the ODFI to the RDFI of the Entry Periodic Reviews of the Same Day Entry Fee will occur and be conducted by NACHA staff at five, eight and 10 years after implementation of the Rule 6

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8 Identifying Same Day Entries Same-day ACH transactions will be identified/processed by the ACH Operator Utilizing Effective Entry Date field Same-day ACH transactions will be identified by the ODFI and its Originator by using the current day s date in the Effective Entry Date field Stale dated and invalid values in this field will also qualify for Same Day processing 8

9 Stale Dated Effective Entry Date Research FRB extracted data for October ,740 total batches examined Number of ODFI s with stale-dated batches: 3,198 Number of distinct company names with stale-dated batches: 28,003

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12 Reversals Reversals will be eligible for same-day processing using the same eligibility criteria as other forward transactions Phase 1 is credits-only, so a debit that reverses a credit Entry will not be eligible for same-day processing during Phase 1 Debits become eligible in Phase 2, so at that time the debit could be same-day Any same-day reversal would be limited to $25,000 per transaction, so if, for example, the erroneous forward credit is a next-day $100,000 credit, the debit to reverse it could not be same day Any reversal that is processed same-day would be assessed the Same Day Entry fee The Effective Entry Date of a debit to reverse a credit Entry or file containing debits must not be earlier than the Effective Entry Date of the credit(s) 12

13 Reversal Examples Phase 1 Reversals (Credits only) A next day debit file was sent yesterday to settle today This morning the Originator calls the ODFI and says that they sent the wrong file The originator could create a Same Day Credit Reversal file that would have the same settlement date as the erroneous Debit file Phase 2 Reversals A credit file was sent as a same day file today and released in the first window Originator realized that they send the wrong file Originator could create a same day debit reversal file and get into the system in the later same day processing window and both entries would have the same settlement dates 13

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16 Scenario 1 In phase 1, a batch is submitted to the ACH Operator at 11:45 pm ET on Tuesday, October 4, 2016, with an effective entry date of October 3, 2016 (stale-dated) Since the batch was submitted prior to the 2:15 am ET deadline and is not future dated, it will settle at 8:30 am ET on Wednesday, October 5, 2016 No same day entry fee will apply

17 Scenario 2 In phase 1, a balanced file with an effective entry date of December 7, 2016, is submitted to the ACH Operator on December 7, 2016 prior to 2:45 pm ET The file contains a single PPD debit entry for $12,500 and multiple PPD credit entries when added together, equal the $12,500 debit entry The credit entries are eligible for same day but the debit is not The credit entries will settle on December 7, 2016 at 5:00 pm ET and the debit entry will settle on December 8, 2016 at 8:30 am The credit entries are subject to the same day entry fee; the debit entry is not

18 Scenario 3 In phase 1, a batch containing PPD entries with an effective date of October 1, 2016, is submitted to the ACH Operator at 2:30 pm ET on October 19, 2016 (the batch is staledated) The batch contains several credit entries and one debit entry for $12,500; one credit entry is for $96,100 and all other credit entries are under $25,000 Assuming there are no edit errors, the batch will be processed at the 2:45 pm ET deadline For the eligible same day entries (the credit entries under $25,000), the output files will be distributed by 4:00 pm ET with settlement occurring at 5:00 pm ET on October, 19, 2016 The credit entry for $96,100 and the debit entry for $12,500 will be included with the 4:00 pm output file, but they will settle the next business day, October 20, 2016 at 8:30 am ET The eligible same day entries will incur the Same Day Entry fee

19 Scenario 4 In phase 2, a CCD entry is submitted to the ACH operator on March 10, 2018 at 2:00 pm ET with an effective date of March 11, 2018 (future dated) The entry is for $23,000 Even though the CCD entry was submitted to meet the 2:45 pm ET same day deadline, the entry was future-dated and will settle on March 11, 2018 at 8:30 am ET No same day ACH entry fee is applied

20 Resources PAR/WACHA- The Premier Payments Resource HELP DESK Phone: Toll Free: Fax: