Same Day ACH: Moving Payments Faster

Transcription

1 Same Day ACH: Moving Payments Faster 2015 NACHA The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only.

2 Same Day ACH Same Day ACH addresses the needs of end-users as an immediate action to modernize the payment system by offering faster posting and funds availability, as well as improved risk management. Same Day ACH provides a foundation of functionality that can be leveraged in the future for real-time payments. 2

3 Same Day ACH Rule Same Day ACH was approved by the NACHA membership on May 18, 2015 The rule builds upon existing, next-day ACH capability to enable a ubiquitous same-day capability for virtually any ACH transaction Creates payment option for the businesses, governments and consumers who want to move their money faster

4 What Is Same Day ACH? The ACH Operators will offer two new same-day processing windows to Financial Institutions 1 A morning window with a deadline of 10:30 am ET for ODFIs to submit files of same-day payments; settlement will occur at 1:00 pm An afternoon window with a deadline of 3:00 pm ET for ODFIs to submit files of same-day payments; settlement will occur at 5:00 pm All RDFIs will be required to receive Same Day ACH payments, thereby giving ODFIs and Originators the surety of being able to send same-day ACH payments to accounts at all RDFIs in the ACH Network RDFIs will make funds available from ACH credits (such as payroll Direct Deposits) to depositors by 5:00pm local time 1 - Times are estimates; exact schedules and timing would be determined by each Operator.

5 What Transactions Will Be Eligible for Same Day ACH? Virtually all ACH transactions will be eligible for same-day processing ACH credits ACH debits Reversals Returns Non-monetary transactions prenotifications, notifications of changes, zero-dollar remittance information transactions, etc.

6 What Transactions Will Not Be Eligible for Same Day ACH? ACH transactions that will be ineligible for sameday processing: international transactions (IATs) large-dollar transactions over $25,000 The $25,000 transaction limit applies to individual transactions; i.e., a single same-day ACH transaction could not be for more than $25,000. There would be no limit on the aggregate value of a batch of same-day transactions. Entries submitted in the same day window that are over $25,000 will not be rejected by the ACH Operator; entries will settle the next day.

7 Phased Implementation Approach 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 Windows 10:30 am ET and 3:00 pm ET 10:30 am ET and 3:00 pm ET 10:30 am ET and 3:00 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 Note: Times are estimates; exact schedules and timing will be determined by each Operator.

8 Major Same Day ACH Uses C2B Bill Pay ecommerce POS check conversion Merchant debit Collections C2C Person-to-Person Account-to-Account B2B Multiple uses, such as trading partner payments, duedate and late invoice payments B2C Payroll Insurance, refunds

9 Some Implementation Topics Origination of Same Day ACH entries Authorization continues to be based on SEC Code Modifications may be needed to authorization process to inform/remind Receiver of same day transaction, if offered Corporate Receiver of Same Day ACH credit entries Must update records to reflect customer s payment as having been received as of date no later than Settlement Date Rules allow a reasonable amount of time to update records

10 Some Implementation Topics Identification of Same Day ACH Transactions Same-day ACH transactions will be identified by using that day s date in the Effective Entry Date field and timely submission into an ACH Operator s same-day processing window Check with ODFI for Originator submission deadlines!! Today s date: Oct. 25, 2016 Batch EED: Batch submitted by 10:30 am ET Batch submitted by 3:00 pm ET Batch submitted after 3:00 pm ET Batch settled 10/25/16, 1:00 pm ET Same Day settlement Batch settled 10/25/16, 5:00 pm ET Same Day settlement Batch settled 10/26/16, 8:30 am Next Day settlement

11 Some Implementation Topics Processing of stale or invalid Effective Entry Dates Same-day ACH transactions with stale or invalid Effective Entry Dates will be settled at the earliest available settlement opportunity Check with ODFI for Originator submission deadlines!! Today s date: Oct. 25, 2016 Batch EED: (stale) Note: stale date means a date that is in the past Batch submitted by 10:30 am ET Batch submitted by 3:00 pm ET Batch submitted after 3:00 pm ET Batch settled 10/25/16, 1:00 pm ET Same Day settlement Batch settled 10/25/16, 5:00 pm ET Same Day settlement Batch settled 10/26/16, 8:30 am Next Day settlement This late file is settled 19.5 hours sooner than with next-day settlement.

12 Some Implementation Topics Return Processing RDFIs will not be required to return transactions on the sameday that they are received Returns will be permitted to be processed through the two new same-day windows Same-day returns will not be subject to the eligibility limits of forward transactions (the per-entry dollar limit, and IATs)

13 Reversals Reversals would be eligible for same day processing using the same eligibility criteria as other forward transactions. Phase 1 is credits-only, so a reversing debit would not be eligible for same day processing during Phase 1. Debits become eligible in Phase 2, so at that time the reversing debit could be same day. Any same-day reversal would be limited to $25,000 per transaction, so if, for example, the forward credit is a next-day $100,000 credit, the reversing debit could not be same day.

14 Is Same Day ACH Right for My Company? Consider business needs Determine ODFI offerings Review current data field usage in file formats

15 Questions? Danita Tyrrell, AAP Director, Network Rules NACHA-The Electronic Payments Association