Questions on Same Day ACH? Let Us Break it Down for You.


  • ALL RDFI’s MUST participate
  • Transactions NOT eligible for same-day activity
    • IAT’s
    • Individual transactions over $25,000

Phase One: Effective September 23, 2016

  • ACH Credits ONLY
  • Two new same-day processing windows in addition to current processing times
    • Submission deadline 10:30am ET, settlement 1:00pm ET
    • Submission deadline 2:45pm ET, settlement 5:00pm ET
  • Funds availability requirement
    • RDFI’s MUST provide funds to receivers by end of processing day

Effective Entry Date Requirements

  • Identified by using the current day’s date in the Effective Entry Date field in the Company/Batch Header Record
  • Example: Transactions originated on Monday, October 10 that are intended for same-day processing and settlement must have an Effective Date of “161010” in the appropriate field and be submitted to an ACH Operator no later than 2:45pm ET
  • Originated entries MUST meet the submission deadline for same-day ACH processing noted above
    • Same Day Entry Fees apply (currently 5.2 cents per originated same-day entry)
  • Additional optional same-day identification can be used for verification between the ODFI and Originator using the Company Descriptive Date as “SDHHMM”. SD denotes same-day processing intention and “HHMM” denotes either 1:00pm or 5:00 pm.  Ex: SD1300 or THIS IDENTIFICATION METHOD WILL NOT BE RECOGNIZED BY THE ACH OPERATOR.

Return Entry Processing

  • Same-day processing of return entries is at the discretion of the RDFI, even if the return was a same-day entry
  • Same-day return entries are exempt from the same-day entry fee
  • Return rules DO NOT CHANGE
    • A return entry must be processed in such time that it is made available to the ODFI no later than the opening of business on the second banking day following the settlement date of the original entry

Impact to Participants

  • RDFI’s
    • Update internal processing applications and procedures to accommodate same-day entries
    • Update file submission and delivery schedules with their ACH Operator
    • Ensure vendors and processors are prepared to handle same-day transactions, including allowing ample time for testing
  • ODFI’s that DO NOT elect to participate
    • Ensure the appropriate use of the Effective Entry Date to prevent inadvertently originating same-day ACH entries
  • ODFI’s that elect to originate same-day ACH
    • Update internal processing applications and procedures to accommodate same-day entries
    • Update file submission and delivery schedules with their ACH Operator
    • If applicable, talk with Originators to determine if they would like to have the advantage of same day origination and settlement. Discuss appropriate business need, cost effectiveness and the optional use of the Company Descriptive Date.
    • Determine fee schedule, if any, for Originators. Provide new fee notifications in the required amount of time.
  • ALL Financial Institutions should notify the appropriate department of the expected ACH billing changes


Still have questions?

Let our resident ACH experts walk you through them by contacting us today at 1(888) 766-1576.

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Procrastinators Beware!

The NCUA has announced they will begin to fine credit unions that submit late call reports. In addition to the requirement for all FICUs to file their reports electronically beginning  January 24, 2014 (that’s in two days for you procrastinators out there),  the NCUA also announced civil money penalties could be assessed for late filers. Any FISCU filing the  January 24th report late will have a warning letter sent to the CEO and Board of Directors. The NCUA states in their January 2014 Report that those that are late with the April filing could face penalties for each day a required report is late or contains inaccurate information. The penalty will vary based on the reason for the delay or inaccuracy, ranging from $10 per day to a maximum of $1 million per day (or one percent of total assets, whichever is less). The NCUA has also stated it will publish the names of those credit unions subject to the fine.

You can access the NCUA Report here.

Below are the filing dates for 2014.

Call Report Cycle
Due Date
December 31, 2013
January 24, 2014
March 31, 2014
April 25, 2014
June 30, 2014
July 25, 2014
September 30, 2014
October 24, 2014
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Is BSA Compliance Still on Your Radar Screen?

If BSA compliance has fallen off your radar in the wake of mortgage rules, remittance transfers and other issues it’s time to refocus. The NCUA recently issued a cease and desist order to North Dade Community Development Federal Credit Union of Miami Gardens, FL. Among other items, the credit union is required to complete the following.

  • Complete a comprehensive bank secrecy/anti-money laundering/foreign assets control risk assessment.
  • Revise and document board approval for all policies relating to bank secrecy, anti-money laundering, and foreign assets control.
  • Ensure staff and officials are adequately trained on all bank secrecy, anti-money laundering, and foreign assets control applicable laws and regulations.
  • Develop a system of internal controls to ensure ongoing compliance with all applicable bank secrecy, anti-money laundering, and foreign assets control laws and regulations.
  • Conduct bank secrecy, anti-money laundering, and foreign assets control compliance program testing.
  • Ensure bank secrecy, anti-money laundering, and foreign assets control testing is complete and results are reported to the board of directors.

Also noted in the cease and desist order is the requirement for the credit union to take care of issues related to their field of membership. Specifically,  the credit union must verify that all members are within the credit union’s field of membership. This is particularly of interest due to the recently issued Letter to Federal Credit Unions 13-FCU-03 that deals with aggressive marketing campaigns by federal credit unions to facilitate membership. We blogged about the letter earlier this week. Credit unions should take note of the continued look into BSA compliance programs and the potential for issues with membership.

You can read the full text of the letter here and read more about the BSA violations here.

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