Originating and Receiving Payments Electronically
It’s an exciting time in the payments industry with several innovative initiatives underway designed to move payments faster! One of these initiatives is NACHA’s “Same-Day ACH Rule” which builds upon existing ACH Network next-day settlement capabilities and establishes a new same-day settlement capability giving businesses an option to send and receive payments faster.
Phased Implementation Approach
Implementation of the “Same-Day ACH Rule” is spread out over three phases that began in September 2016. This phased approach provides an eighteen-month period over which businesses and financial institutions can manage their implementation efforts. This allows the industry to gradually acclimate to a faster processing environment.
- The first phase was implemented on September 23, 2016, and provided for same-day settlement of domestic ACH credit entries of $25,000 or less with funds being available by end of the Receiving Depository Financial Institutions (RDFI's) processing day.
- The second phase of implementation will occur on September 15, 2017, and will enable same-day settlement of domestic ACH debit entries of $25,000 or less. Same-day credit funds availability will remain at the end of the RDFI's processing day.
- Finally, in the third phase, effective March 16, 2018, RDFI's will be required to provide funds availability for same-day credits no later than 5:00 p.m. in the RDFI’s local time.
The federal government did not participate in phase one of the same-day ACH credit implementation. Therefore, any entry originated from, or received by, the federal government today, is not be eligible for same-day settlement and is being settled on a future date. For example, federal tax payments do not currently qualify for same-day ACH settlement.
Important Update: The federal government has operationally committed to participating in same-day ACH as of September 15, 2017, beginning with the capability to receive tax and non-tax same-day ACH credits.
If you originate ACH transactions, here are facts you need to know to prepare for upcoming changes to accommodate same-day ACH:
- Beginning September 15, 2017, domestic ACH debit entries of $25,000 or less, originated by you that meet the following criteria will be processed and settled as same-day ACH transactions.
- Dated with the current day's date in the Effective Entry Date field. Please note, stale or invalid dates in the Effective Entry Date field will be processed in the next available window, which could be same-day or next-day; and
- Received for processing by 12:30 p.m. CT for Direct Send clients and by 12:00 p.m. CT for AmegyConnect clients.
- To avoid same-day processing, submit your file after the cutoff time referenced above or use an Effective Entry Date in the future.
- Domestic transactions greater than $25,000 and international transactions do not qualify for same-day processing.
- Same-day ACH transactions are assessed an additional per item fee of $1.00. Please note, the Same-Day Transaction Fee only applies to transactions going to banks other than ZB, N.A and its divisions.
- We recommend reviewing and updating the ACH Debit Authorization Form signed by your customers, if necessary, so that it addresses the possibility of same-day settlement.
If you receive ACH debit transactions in your account, here are facts you need to know to prepare for upcoming changes to accommodate same-day ACH:
- Beginning September 15, 2017, domestic ACH debits (up to $25,000) may post the same day as submitted.
- As a best practice, companies receiving ACH debits should account for anticipated transactions to ensure sufficient funding.
Important Product Changes to Accommodate Same-Day ACH
FINANCIAL ELECTRONIC DATA INTERCHANGE (FEDI)
If you use our FEDI service, here are facts you need to know to prepare for upcoming changes to accommodate same-day ACH:
Clients Receiving FEDI Translated Reports via AmegyConnect or Facsimile
- Effective August 7, 2017, dependent on your received activity, you could begin receiving a second report each day.
- You will continue to receive the morning report at 8:00 a.m. CT which includes items received up until 3:00 a.m. CT with a settlement date of current day.
- Beginning, August 7, 2017, you may receive a second report at 4:00 p.m. CT which will include any items received from 3:01 a.m. CT – 3:45 p.m. CT with a settlement date of current day. Please note, the second report will only be sent if you have same-day items.
- There is no additional fee to receive the second report within AmegyConnect.
- Please note, the standard per-page fee will apply for the second report received via Facsimile.
Clients Receiving FEDI NACHA Files via Direct Send (SFTP)
- As you do today, you will continue to receive the morning file at 8:00 a.m. CT which includes:
- Current day's settlement date items
- Previous day's Same-Day items
- If you prefer to receive two separate files or one file after 4:00 p.m. CT, please contact Treasury Management at 713-235-8805.
ACH POSITIVE PAY
If you use our ACH Positive Pay service, here are facts you need to know to prepare for upcoming changes to accommodate same-day ACH:
- Effective September 15, 2017, we will begin loading ACH Positive Pay exceptions twice a day.
- We will continue to load exceptions at 7:00 a.m. CT which includes exceptions from ACH items received up until 3:00 a.m. CT with a settlement date of current day.
- Beginning September 15, 2017, we will also load exceptions at 4:00 p.m. CT which will include exceptions from ACH items received from 3:01 a.m. CT - 3:45 p.m. CT with a settlement date of current day.
- So that you have sufficient time to decision your exceptions, the decision window is being extended to 6:00 p.m. CT. Please note, if you do not provide a decision by the cutoff time, your default decision (Pay or Return) that you established at implementation will apply.
- We recommend decisioning your exception items twice a day, once in the morning after the first exception load and then again after the afternoon exception load. Most of your exceptions will continue to be in the morning load.
- If you have enabled Email Notifications, you will receive notifications at the following intervals to help manage your exception items:
- At start of decision window - 7:00 a.m. CT
- When same-day ACH exceptions have been loaded - 4:00 p.m. CT
- 30 minutes before decision window ends - 5:30 p.m. CT
- There is no additional ACH Positive Pay fee for the second exception load or the extended decision window. Please note, the standard per-item exception fee and the standard per-item exception return fee will apply.
We Are Here to Help
We will continue to share more information as September approaches to help you prepare for the next phase of same-day ACH. Please click here to view our Same-Day ACH Service Referenece Guide.
Please contact our Treasury Management department at 713-235-8805 if you have any questions.
*If you use AmegyConnect® to originate ACH transactions, you must be enrolled in Same Day ACH to take advantage of same-day settlement.