HERNDON, Va.—The second phase of same day automated clearing house (ACH) rollout has a Sept. 15 effective date, and NACHA—The Electronic Payments Association, has released a list of recommended action items to be performed before that date.
All financial institutions must be prepared to receive same-day ACH debits by Sept. 15, even if not originating them, reminded CUNA.
“NACHA emphasizes that “even those not planning to use same-day processing for ACH debits should take reasonable care to prevent unintentional same-day ACH debits," CUNA stated in its analysis.
Other action items include:
-
All originators should “check and correct” the Effective Entry Dates in ACH transactions they originate, even those that do not intend to make use of same-day debits.
-
All originators that intend to make use of same-day ACH debits should review authorization language to ensure that the terms are clear and readily understandable regarding the timing of such debits.
-
All originating depository financial institutions (ODFIs) should identify and contact originators that currently use incorrect effective entry dates in their ACH debit transactions, or otherwise act to address such originators’ use of incorrect effective entry dates.
-
All third-party senders, ACH software vendors and ACH payment processors should assess their own roles in ensuring accurate processing, including accurate dating of transactions.
- ODFIs can contact their ACH operator(s) for additional assistance, tools and reports regarding Same Day ACH.