16 Hoosier Banker May 2016 deadline of 10:30 a.m. Eastern time (1 p.m. settlement), and an afternoon submission deadline of 2:45 p.m. ET (5 p.m. settlement). The same-day ACH rule includes a “same-day fee” on each same-day ACH transaction for RDFIs, in order to recover some of their costs associated with enabling and supporting the process. When Is the Deadline to Comply? Same-day ACH is being implemented in three phases: • Phase 1 begins Sept. 23 of this year, with ACH credits only; • Phase 2 begins Sept. 15, 2017; in this phase, same-day ACH debits may be transmitted through the network; • Phase 3 kicks off on March 16, 2018, mandating that all RDFIs make funds available from sameday ACH credits (such as payroll direct deposits) to their depositors by 5 p.m. of the RDFI’s local time. About the Author Jennifer Kirk is vice president, industry and government relations, for EPCOR, a not-for-profit trade association providing electronic payments and risk management information, education, support and national industry representation to U.S. financial institutions. 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. The industry has spoken. Beginning in September, sameday Automated Clearing House (ACH) will be a reality, bringing us one step closer to moving payments faster within the United States. Below are some questions and answers to help banking professionals prepare. Will Same-Day ACH Affect Me? The short answer is yes! All receiving depository financial institutions (RDFIs) are required to receive same-day ACH entries. However the volume your institution will receive remains to be seen. Many ACH transactions will continue to settle within the traditional two-day ACH credit and one-day ACH debit model that exists today. An originating depository financial institution (ODFI) will be able to submit files of same-day ACH payments through two new clearing windows provided by ACH operators: a morning submission Can I Opt-Out? Now that same-day ACH rules have passed, and the Federal Reserve has announced its support, rumors are flying as to who must comply with same-day ACH. The truth is simple: Every single receiving depository financial institution must comply. If you are an ODFI, you have the choice to originate same-day ACH items, but RDFIs must receive them. Who Will Help Me? Your core processor or data processor should already be preparing to support same-day ACH. Your processor most likely is working on ways to help you automate processes to ensure that your accountholders will get their money on time, with minimal impact to your staff. Correspondent banks also are working to make sure that your needs are met, so that you can continue to comply with ACH rules throughout the phases of implementation. Additionally your regional payments association, such as EPCOR, is working diligently to ensure that training and support are easily understood; your payments association also will help you sort out how these rules will impact your financial institution’s internal policies and procedures. t OPERATIONS / TECHNOLOGY Setting the Record Straight on Same-Day ACH Compliance Note: Jennifer Kirk is presenting a “Same-Day ACH Symposium” on June 21 at the Indiana Bankers Association Center for Professional Development. For more information, contact Laurie Rees at 317387-9380, email: lrees@indianabankers.org.
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