Same Day ACH Progress Report Looking Ahead. Ryan Waterman, AAP, AVP, Risk & Regulatory Compliance
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1 Same Day ACH Progress Report Looking Ahead Ryan Waterman, AAP, AVP, Risk & Regulatory Compliance
2 Ryan Waterman, AAP ACH Audits, Hotline Calls, and Risk Management AVP, Risk & Regulatory Compliance Responsible for conducting ACH audit and risk assessments and providing risk and compliance education to WesPay s members Served as Vice-Chair of WesPay s Rules Advisory Council Has over a decade of experience in community banks with a focus in the commercial banking and payments industry Served on WesPay s Risk Management Advisory Council When he s not working, you can find Ryan on horseback or floating on the lake. 3
3 WesPay, as a Direct Member of 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 the Accredited ACH Professional (AAP) program. This material is derived from collaborative work product developed by NACHA The Electronic Payments Association and its member Regional Payments Associations. This material is not intended to provide any warranties or legal advice, and is intended for educational purposes only Western Payments Alliance (WesPay). All rights reserved. NACHA owns the copyright for the NACHA Operating Rules & Guidelines. The Accredited ACH Professional (AAP) is a registered service mark of NACHA. 4
4 Same Day ACH Phase 2 Functionality Phase 1 September 23, 2016 Phase 2 September 17, 2017 Phase 3 March 16, 2018 Transaction Eligibility Credits Credits & Debits Credits & Debits Processing Deadlines 10:30 am ET & 2:45 pm ET 10:30 am ET & 2:45 pm ET 10:30 am ET & 2:45 pm ET New Settlement Times 1:00 pm ET & 5:00 pm ET 1:00 pm ET & 5:00 pm ET 1:00 pm ET & 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 5
5 Same Day ACH Phase 1 6
6 SDA Identification 1. Passenger needs right ticket for trip they want Originator needs the right SDA format Effective Entry Date = Today s date (or stale date) + = S D A 2. Passenger needs to be at correct station on time Originator submits file to ODFI by SDA deadline ODFI submits file to Operator within SDA window 7
7 Same Day ACH Phase 1 Stale Dated Items? Forward Credit & Return Entries? Settlement Issues? Use Cases? 8
8 Reminders About Processing Returns 9
9 Same Day ACH Phase 2 Functionality Phase 1 September 23, 2016 Phase 2 September 17, 2017 Phase 3 March 16, 2018 Transaction Eligibility Credits Credits & Debits Credits & Debits Processing Deadlines 10:30 am ET & 2:45 pm ET 10:30 am ET & 2:45 pm ET 10:30 am ET & 2:45 pm ET New Settlement Times 1:00 pm ET & 5:00 pm ET 1:00 pm ET & 5:00 pm ET 1:00 pm ET & 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 10
10 Reminders About Processing Returns» Late afternoon return window Submission between 2:45 pm 4:00 pm ET 5:00 pm ET distribution o Will contain returns only! 5:30 pm ET settlement AJ19 application ID Can include treasury or commercial items 11
11 Same Day ACH Phase 2 Survey 12
12 Uses for Same Day ACH Debits» Low Risk Payments Still possible returns» Consumer billing Due date / late payments o Payments to prevent loss of service» Check conversion Merchants and lockboxes» Collections» Business-to-Business Just-in-time payments for release/shipment of goods Invoice due date / late payments 13
13 ACH Operators Offering Phase 2 Testing» Recommended for all parties Don t assume because your business partner has tested that you are covered» Include more than just file pick up Posting Downstream applications Reconcilement with operator and accountholders» Schedules provided by Operators 14
14 Same Day ACH Phase 2 RDFI CONSIDERATIONS 15
15 RDFI Considerations» Posting Timing & Order Reputational risk for variable EOD times? Posting order o Timing of returns o Expectations of consumers» Settlement Liquidity (visibility of future settlement position) SDA returns impact 16
16 Additional RDFI Considerations» Stop Payments Reasonable opportunity to act shortens Volume shift to Reg. E disputes (WSUD)?» Reporting Need for additional reporting to Corporate Receivers to provide visibility to SDA window volume o Positive Pay o Cash Management Reporting o Impacts to online & mobile channels Corporate SDA Receivers must update records to indicate payment in reasonable time o Reliance upon RDFI for information 17
17 RDFI Call to Action» Understand schedules for mandatory receipt of sameday entries Operator delivery schedules will not change from Phase 1» Determine how and when to post received same-day debit entries» Review corporate reports, Treasury Management and online banking systems for Same Day ACH integration» Communicate with corporate customers on file delivery including remittance and posting requirements» Ask vendors and processors about support 18
18 Same Day ACH Phase 2 ODFI CONSIDERATIONS 19
19 Processing Considerations» Reversals SDA can increase chances of original Entry and reversal posting same day Reversal cannot settle prior to original Entry o If ODFI creates reversal: code or procedures needed o If Originator creates reversal: what is ODFI s control? Benefit of originating in 1 st SDA window o Reversals can process in 2 nd SDA window of day 20
20 Processing Considerations» Reinitiations (Redeposits) Will ODFI offer SDA reinitiations? o Value in redeposit posting ASAP? o SDA fee applies» Balanced files If settlement Entries sent to ACH Operator: o $25K per SDA Entry limit 21
21 SEC Code Considerations» Language in e-check notifications that debit may clear same-day o ARC o BOC o POP o RCK» TEL Notification of single TEL Authorization must be sent prior to settlement of Entry (revised Subsection )» Originators should review disclosures & ensure they can provide same-day settlement to customers/partners 22
22 ODFI Call to Action» Decide which Same Day ACH Debit services will meet the needs of various accountholders Business vs. Consumer Understand use cases Same Day ACH is an option for both which clients and which standard Entry class codes to support» Ensure correct identification of same-day transactions Review effective Entry dates used by corporates Debits on Day 1 of Phase 2 implementation Decide if you will use the optional identifier 23
23 ODFI Call to Action» Communicate with corporate originators Use cases Correct formatting» Review corporate reports, Treasury Management and online banking systems for Same Day ACH integration» Discuss support options with vendors and processors 24
24 Corporate Call to Action» Evaluate new opportunities to originate same-day debit payments Same Day ACH is an option to discuss with your financial institution» Effective date needs to be accurate, even if you are not originating same-day transactions Do not be an unintentional Same Day ACH Originator» Understand potential impact on cash position Phase 1 limited to credits Phase 2 includes credits and debits Transaction limit of $25,000 25
25 Same Day ACH Phase 3 Functionality Phase 1 September 23, 2016 Phase 2 September 15, 2017 Phase 3 March 16, 2018 Transaction Eligibility Credits Credits & Debits Credits & Debits Processing Deadlines 10:30 am ET & 2:45 pm ET 10:30 am ET & 2:45 pm ET 10:30 am ET & 2:45 pm ET New Settlement Times 1:00 pm ET & 5:00 pm ET 1:00 pm ET & 5:00 pm ET 1:00 pm ET & 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 26
26 Phase 3 (Effective March 16, 2018)» Subsection RDFI May rely on Settlement Date RDFI may rely on Settlement Date of Entry, regardless of Effective Entry Date» Subsection General Rule for Availability of Credits Remain unchanged from existing Rules For Phase 3 Same day credit Entries must be made available to Receiver for withdrawal no later than 5:00 p.m. in the RDFI s local time on the Settlement Date of Entry» NACHA s guidance on local time : The Rule does not specify a required method of calculating local time in order to allow RDFIs flexibility in using a consistent standard that is most easily applied in an RDFI s specific processing environment 27
27 Funds Availability Same-Day Credits Effective: March 16, 2018» Atlantic Time Zone Puerto Rico, U.S. Virgin Islands Required to make funds available to Receiver for withdrawal no later than 5:00 p.m. Eastern Time (6:00p.m. Atlantic/local time)» Chamorro Time Zone Guam, Northern Mariana Islands Required to make funds available to Receivers for withdrawal no later than opening of business on the Banking Day following the Settlement Date of the Entry. 28
28 Resources» WesPay Same Day ACH Resource Page ACH/WesPayPublic/Risk_Compliance/Same_Day_ACH.aspx?hkey=93e a72-4f74-bf5b-d43e472a4657» NACHA Same Day ACH Resource Center SDA Debits-Guidance for RDFIs Guidance-for-RDFIs.pdf» FRB SDA Testing Information 29
29 Questions? 30
30 Please contact us at: 300 Montgomery St, Suite 450 San Francisco, CA Phone: Fax: Payments Hotline or info@wespay.org 31
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