NACHA Same Day ACH Survey Results
By Brian Stearns, AAP, NCP, AVP, Risk & Regulatory Compliance
Posted: July 12, 2016
NACHA recently conducted a survey of their direct members and 2015’s top 50 ACH Receiving Depository Financial Institutions (RDFIs) to determine their readiness and implementation plans for Same Day ACH. A total of 44 financial institutions provided their responses to the four questions below, representing 61% of commercial ACH network received volume.
Question 1: Will your institution be ready to receive Same Day ACH credits on Day 1? (September 23, 2016)
All 44 respondents indicated that they will be ready to receive Same Day ACH credits on day 1 of implementation, September 23, 2016.
Question 2: In Phase 1 will your financial institution post credits from the first same day window earlier than credits received in the second same day window (i.e., post by window)?
75% of respondents (33 responses) indicated they will be posting credits from the first window earlier than those in the second window. RDFIs that plan to post the contents of both Same Day ACH files together in the evening should be aware they will be providing later availability to these funds than many of their competitors.
Question 3: In Phase 1, what time will you post/make funds available to your customers?
The most common answer RDFIs provided was “5:00 p.m. local time” followed by “shortly after each window.” Times ranged from 15 to 120 minutes after receipt from the ACH Operator, with “60 minutes” being the second most common answer. RDFIs that answered “no” to question two (those who are not posting separately by window) most commonly indicated funds availability would occur via their hard post process during their end-of-day, with times ranging between 8:00 p.m. to 2:00 a.m. local time.
Question 4: When will you meet the Phase 3 customer funds availability requirement of 5:00 p.m. local time?
70% of RDFIs plan to meet the Phase 3 funds availability requirement of 5:00 PM RDFI local time upon implementation of Phase 1. These RDFIs either already have the capability to make Same Day credits available by the Phase 3 availability requirement, or have decided it was more effective approach to undertake a single implementation effort to comply with the Phase 3 availability requirements at the outset.
While the 44 institutions participating in this survey represent a relatively small sample size of all U.S. Receiving Depository Financial Institutions, their collective received volume accounts for the majority of annual ACH commercial network received volume, indicating that most corporate and consumer account holders won’t have to wait until Phase 3 to receive availability to their Same Day ACH credits before 5 p.m. local time. Awareness of what their competitors are planning may be a deciding factor for RDFIs debating when they will provide Same Day ACH credit availability to their account holders.