2018 NACHA Rules Updates

2018 ACH Rules Amendments Summary

As part of our commitment to keep our Automated Clearing House (ACH) origination customers informed of changes regarding ACH electronic payments, we are providing you the following summary of the 2018 Operating Rules changes by NACHA - The Electronics Payments Association®.

This summary has been tailored to provide the impacts of the upcoming rule changes to the most common types of corporate origination services. It is not intended to replace the detailed analysis we encourage your organization to perform to determine the specific impact these changes may have on your ACH origination processes.

This document contains a brief description and summary of each of the 2018 ACH Rules Amendments and their potential impact on typical ACH origination processes:

1. Same Day ACH - Moving Payments Faster, Phase 3 (Effective March 16,2018) 

More information about these amendments can be found in either the full or corporate version of NACHA’s ACH Operating Rules and Guidelines. We strongly recommend you obtain a copy each year to use as reference and to ensure you are in compliance with the responsibilities of Originators contained within 2016 NACHA Operating Rules & Guidelines. Copies of NACHA’s guidelines can be found at NACHA’s eStore at https://www.nacha.org/estore/home.

2018 ACH Rule Amendments Potentially Impacting Originators

1. Same Day ACH - Moving Payments Faster, Phase 3 (Effective March 16, 2018)

Summary

Phase 3 of the Same Day ACH rules require all Receiving Depository Financial Institutions (RDFIs) to make Same Day ACH credits available to their Receivers no later than 5 p.m. in the RDFI’s local time.

Details

Prior to Phase 3, RDFIs were required to make Same Day ACH credits available by their end-of-day process. This final phase of the Same Day ACH rollout which began with the introduction of Same Day ACH credits in September 2016, followed by Same Day ACH debits in September 2017, promotes a more consistent experience for Receivers across the country, in that all RDFIs will be required to make received Same Day ACH credits available to them by 5 p.m. in the RDFI’s local time.

More information about the details of Same Day ACH can be found on NACHA’s website: https://www.nacha.org/rules/same-day-ach-moving-payments-faster-phase-3.

Contact your Treasury Management Sales Consultant for more information related to originating Same Day ACH.

Originator and Third-Party Sender Impact

There are no changes required of Originators and Third-Party Senders who are utilizing Same Day ACH today. Phase 3 of the Same Day ACH rules promotes a more consistent experience for the Receivers of Same Day credit entries. Originators and Third-Party Senders can expect that any Same Day ACH credit entry originated that day will be available to the Receiver by 5 p.m. in the RDFI’s local time.

In addition to the new rules, all Originators and Third-Party Senders should be sure to follow the general requirements specified in the ACH Rules including:

Sections referenced are located in 2018 NACHA Operating Rules & Guidelines.

1. Obtaining proper authorization from its Receivers in compliance with Section 2.3.2 of the ACH Rules

2. Retaining the original or copy of each written authorization of a Receiver, or a readily and accurately reproducible record evidencing any other form of authorization for at least two years from the termination or revocation of the authorization according to Subsection 2.3.2.5 of the ACH Rules.

3. Providing proper and timely notice to Receivers for changes to the amount or scheduled date of recurring debits according to Subsection 2.3.2.6 of the ACH Rules.

4. The proper way to initiate pre-notification entries, if the Originator chooses, as specified in Section 2.6 of the ACH Rules.

5. The proper way to reverse files or entries as specified in Section 2.8 and 2.9 of the ACH Rules.

6. Familiarity with the proper actions to take upon receipt of any returns or Notifications of Change including if they choose to reinitiate any returns an additional time in accordance with Section 2.12 of the ACH Rules.