CCUL Headlines: Compliance

CUNA: 2nd Phase of Same Day ACH begins Friday

Wednesday, September 13, 2017   (0 Comments)
Posted by: CUNA News
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Editor’s Note: This article was originally featured on CUNA News September 11, 2017 and has been modified.

The second phase of same day automated clearing house (ACH) rollout begins Friday, and even credit unions not planning to originate same-day debits need to be prepared. All financial institutions must be prepared to receive same-day ACH debits by Friday, even if not originating them.

Glen Sarvady of Best Innovation Group addresses several things credit unions should be thinking about as the deadline approaches in a recent CUNA CompBlog post.

Since all financial institutions need to receive these payments, credit unions and other financial institutions cannot control whether such transactions hit members’ statements. However, credit unions can and should control the member experience by standing ready to recognize issues and answer questions as they arise.

The largest potential glitch stems from ACH origination files containing “stale dated” transactions. In the past, these payments typically processed on the next available date. Starting Friday, they could conceivably be misconstrued as a same-day transaction.

Operational decisions receiving CUs must also make include:

  • Reaching out to processors and vendors to confirm how same-day transactions will appear on member statements and explore any other special situations that might arise;
  • Deciding on how to deal with posting order and funds availability. While ACH rules require financial institutions to receive same-day debits starting Friday, same-day funds availability is not mandated until 2018;
  • Potentially inspecting incoming ACH files for anomalies in the “effective entry date” field that may trigger inadvertent same-day processing.

The final rule from the Federal Reserve, outlining federal government participation in ACH, was published in the Federal Register Monday, September 11, 2017.

Source: CUNA News

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