20 Hoosier Banker August 2015 OPERATIONS On May 18 the NACHA membership approved a new ACH* rule on Same Day ACH. This rule will be implemented in three phases, with Phase 1 going into effect in September 2016. In preparation, there is plenty a bank can be doing now to get ready for this epic change. Following is a “top five” list of steps to be taking: 1. Become familiar with the Same Day ACH Rule. This is a phased implementation approach, and Same Day ACH credit funds availability rules are not defined until Phase 3. Meantime there is much conjecture and hearsay about the Same Day ACH Rule. Make sure you know what the rule actually says by accessing the new rules language at: nacha.org/rules/ same-day-ach-moving-paymentsfaster. 2. Anticipate the staffing impact of Same Day ACH. Work with your processors to see what they plan to automate, and what will be manual for your bank. Since this rule is *Automated Clearing House About the Author Jennifer Kirk is director, industry relations, for EPCOR, a regional payments trade association. She joined the organization in 2002 and has served as a member of the NACHA Rules and Operations Committee, NACHA Blue Ribbon Panel, NACHA Arbitration Board and as co-chair of the National ACH Forum Education Committee. Kirk is an accredited ACH professional and earned an MBA from Ohio University. The author can be reached at 800-500-0100, email: jenk@epcor.org. Five Steps to Take to Prepare for Same-Day ACH completely new, you must expect the unexpected. 3. Understand that this rule is mandatory for receiving depository financial institutions (RDFIs), which will not be able to opt out of NACHA’s Same Day ACH rules. RDFIs must plan to accept same-day credits and debits, and must follow the ACH rules as they pertain to funds availability, posting and exception processing. 4. Begin discussions on whether to allow originators to send Same Day ACH. This is intended to be a premium service to your originators. This service is ideal for contingency on missed payroll files, but are there other use cases for Same Day ACH that may generate revenue for your bank? Do you have business clients who would benefit from this service? Just as with any ACH origination services, there is no mandate to offer Same Day ACH origination services. 5. Look for resources, tools and education from your regional payments association, which through its relationship with NACHA, has been tracking the Same Day ACH Rule proposal. If it has not already done so, it will be offering training, newsletter articles, tools and resources to help financial institutions implement Same Day ACH. Information about your regional payments association is available at: nacha.org/members/ regional-payments-associations. t
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