Q: What is Same Day ACH?
A: The National Automated Clearinghouse Association (NACHA) has adopted a rule to provide a new capability for moving ACH payments faster. The rule enables the same day processing of most ACH payments. Currently, most ACH payments are settled on the next business day. This changed with the ability for eligible credit files to be settled the Same Day starting September 23, 2016. ACH debit files will be eligible to settle as Same Day transactions starting September 15, 2017, Additional changes related to Same Day processing are outlined below.
Q: What types of ACH payments are eligible for same day processing?
A: According to NACHA, 99% of ACH transactions are eligible for same‐day processing. Only international transactions (IATs) and transactions above $25,000 are not eligible.
Q: When will the three phases of the rule be implemented?
Q: Will government payments be eligible for same day processing?
A: On September 11, 2017, the Department of Treasury's Fiscal Service published a final rule at 31 CFR Part 210, “The Federal Government's Participation in the ACH.” The rule addresses changes made by NACHA – The Electronic Payments Association since 2013. In its final rule, the Fiscal Service adopts most of the rule changes made by NACHA during this timeframe, including changes to accept and authorize Same Day ACH. Starting on September 15, 2017, Fiscal Service will begin accepting Same Day ACH credits for tax and other payments to federal agencies. Fiscal Service also expects to enable the use of Same Day ACH debits for tax collections in 2018 and begin originating Same Day ACH credits as payments in December 2017.
Q: Will non‐monetary ACH transactions be eligible for same day processing?
A: The following non‐monetary ACH transactions will process same day if submitted within the processing windows:
Q: Will the current ACH processing schedule change?
A: The rule will enable the option for Same Day ACH payments through new ACH Network functionality, without affecting existing ACH schedules and capabilities. Johnson Bank clients who have contracted for Same Day ACH origination will be able to submit files through two new submission deadlines, 9:00 a.m. and 11:30 a.m. CT, in order to be considered for same day processing.
Q: Is there an additional fee for originating Same Day ACH payments?
A: Yes, there is a different pricing schedule for Same Day ACH origination. Please contact your Treasury Management Relationship Manager for pricing information.
Q: How do I sign up for Same Day ACH?
A: Contact your Treasury Management Relationship Manager for more details on Same Day ACH.
Q: Can I block my account from Same Day ACH?
A: You cannot block your account from Same Day ACH Origination. To ensure your file does not process same day, double check that you have the date you want the file to be effective in the effective entry date field in your file prior to sending over to Johnson Bank.
For ACH Receipt, all Receiving Depository Financial Institutions (RDFIs) are required to receive and process same day ACH payments according to NACHA rules.
Q: Is the over $25,000 value limit applied to a single item or to a file?
A: The transaction limit of $25,000 applies to a single item, not a file. In addition, transactions may not be restructured or split to evade the $25,000 limit. For example, if a business has a loan payment of $50,000 due, that payment would not be eligible for Same Day ACH and should not be divided and sent as multiple same day entries in order to avoid the per‐transaction dollar limit. Dividing a higher‐value payment into separate transactions to get around this limit is an ACH rules violation.
Q: What happens if a file submitted for same day settlement contains one or more item(s) over $25,000?
A: All items in the file will be processed, and the item(s) over $25,000 will be assigned the next business day's settlement date, whereas the remaining items will receive same day settlement.
Q: If I send a Same Day ACH payment for processing, when will my account be debited or credited for the ACH file?
A: If you originate a Same Day ACH Credit or Debit, your account will be debited or credited the same day you originate the transaction, at approx. 9:30 a.m. or 12:30 p.m. CT depending on the time your file is received.
Q: How important is the effective entry date?
A: With the introduction of Same Day ACH, the effective entry date in your file is critical. Assuming the file is submitted by the appropriate deadline, it is the effective entry date field that triggers same day settlement for eligible transactions. The current processing day in the effective entry date field, is interpreted as an intentional indication of the desire for same day settlement whether the effective entry date field contains the current processing date, or is invalid or stale. NOTE: Items that settle before the recipient expects them are eligible to be returned as “unauthorized.” The originator is then required to obtain a new signed authorization to originate future transactions.
Q: How can I ensure items not intended for same day settlement are processed properly?
A: You should include a future date in the effective entry field to ensure future day settlement. ACH files created with today's date and sent before 11:30 a.m CT may be processed as a Same Day ACH files, and applicable fees will apply.
Q: How do I change the effective entry date on my file?
A: If you use software to create a NACHA formatted ACH file, work with your provider to ensure the software applies the effective date either Same Day or Future Day depending on when you want your ACH files to process. If you elect to send Same Day ACH files, work with your Treasury Management Relationship Manager to sign up for the Same Day ACH service.
If you use Business Gateway® to create a NACHA formatted ACH file, the system is ready. If you would like to originate Same Day ACH files, work with your Treasury Management Relationship Manager to sign up for the Same Day ACH service.
Q: What will happen if I continue to send same day or stale dated files and have not signed up for Same Day ACH?
A: If your file is received prior to 11:30 a.m. CT, it could be processed same day and you will be charged Same Day ACH fees. If you continue to send same day or stale dated files, you will be opted in for Same Day ACH so your files will process normally as Same Day ACH files.
Q: If I receive a Same Day ACH Credit or Debit, when will I see it in my account and how will I know it was a Same Day ACH?
A: Same Day ACH Credits and debits received to your account will post by the end of the bank's posting day. You may see the transaction as pending in your account as soon as it is received by the Receiving Depository Financial Institution (RDFI). The transaction will post to your account with the same type of transaction description and details as the ACH Credits and Debits that currently post to your account today.
Q: What happens if I send a Same Day File and didn't mean to?
A: Contact the bank right away to determine what options are available, such as deletion or reversal. In addition, contact the parties for which you sent the transactions to make them aware of the situation and confirm if they will accept the transaction.
Q: If I have ACH Positive Pay (ACH Debit Filter), how will I be notified of unauthorized Same Day ACH Debit exceptions?
A: Starting September 15, 2017, ACH Positive Pay exceptions may occur at approx. 11:00 a.m. and 3:00 p.m. CT. If an ACH Positive Pay exception is identified, Johnson Bank will contact the Positive Pay administrator by phone to obtain decisions on the exceptions prior to 4:30 p.m. CT.
Starting October 23, 2017, clients will be notified of the exception through automatically through the Positive Pay system. Users authorized to decision ACH Positive Pay exceptions will receive an email or text message alert to notify them of the pending exception. Decisions for Same Day ACH Positive Pay exceptions must be completed through the Positive Pay system no later than 5:00 p.m. CT. If exception decisions are not received by 4:00 p.m. CT, an ACH Positive Pay exception reminder alert will be generated.
For more information, please view our recent article highlighting the second phase of Same Day ACH.