Getting Deadline Ready

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Five strategies to score with same-day ACH transactions

By Sean Carter

September’s crisp air signals the start of football frenzy. But for community banks, the month also marks a significant change in payments: the start of the implementation of rules to process same-day Automated Clearinghouse payments.

Same-day ACH payments will level the playing field for financial institutions, offering faster payments to customers. By adding two same-day settlement windows to the ACH Network, we will increase the movement of funds between financial institutions to three times each day—speeding up ACH payments for everyone. 

Countdowns at community banks to operationally prepare for same-day ACH transactions have begun. In fact, a recent survey of New England ACH Association members showed that the majority is in evaluation mode, with only a few ready for implementation. But pretty soon that statistic will quickly flip, and every bank will be speeding toward the Sept. 23 compliance deadline, the first of three same-day ACH payments implementation deadlines.

So you may be asking, what should our community bank be doing now? And what should it be doing next month? And the month after? While each financial institution is different, five key strategies compose a winning game plan.

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Strategy 1: Play strong from the start. A good strategy looks at the desired end state and unfolds to that goal. If your community bank implements Phase 1 with its approach for Phase 3 in mind, your bank will be ahead of the curve to introduce new opportunities and help shape your bank’s playbook for same-day transactions.

Strategy 2: Go long. Consider the bigger picture, even when you’re up to your eyeballs in operations. Thinking ahead will put your community bank in the lead early in the game. Same-day ACH transactions will provide a concrete way to move more payments more quickly, train your customers and staff to work with faster schedules, and help prepare for the advent of real-time payments.

In addition, same-day ACH transactions tempt you to look at new origination opportunities. What benefits would that create for your customers? What business opportunities would it generate for you?

Strategy 3: Practice early and as a full team. The old adage “practice makes perfect” applies. Start running scenarios with your community bank’s team and preparing for day one—Sept. 23. The sooner, the better.

First, you’ll want to explore the impact of the schedule change on different operational areas of your bank. If your team works directly with the Federal Reserve, your bank may not need to engage a processor; instead, it may need to consider the effects of external software needs on internal information-technology workloads.

If your bank has a processor, it will have to rely upon the transaction-clearing schedule it provides. If that is the case, your bank should address other nonoperational tasks while you’re waiting for the processor. Consider your colleagues handling downstream applications, such as bill payments, remittances and return-and-notice-of-change deliveries. What modifications need to be made to their processes? Also evaluate impacts to frontline staff. What changes are needed to your bank’s disclosures, including discussions of timing on the deposit and language around overdrafts? What training is needed to create clarity?

Your ACH processor sets the upgrade time frame, but your bank has power over its internal operations. Focus on business impact, and leave the nuts and bolts of execution to your processor.

Strategy 4: Block and tackle to manage risk. With any new opportunity comes added risk. But without risk, there’s no reward. Faster processing with same-day ACH transactions requires additional controls and monitoring. Specifically, community banks should understand the implications to their current processes, risk-management issues and communications.

Cast a cautious eye toward same-day ACH returns and how late-day credits and debits will affect customers. Remember same-day ACH also helps tackle risk: Faster return time frames reduce exposure by speeding up all returns.

Your Same-Day ACH Playbook

NACHA—The Electronic Payments Association has developed tools and resources to support community banks as they prepare for same-day ACH implementation. The full playbook includes:

  • implementation checklists for both originating depository financial institutions and receiving depository financial institutions;
  • detailed explanations of effective entry date and return processing scenarios; and
  • guidance on transaction limits, end-of-processing-day details, and 5 p.m. local time requirements.

To access these resources, visit NACHA’s website at nacha.org/same-day-ach.

Strategy 5: Keep flags at bay and comply. Not meeting the implementation schedule puts your community bank out of play before the game begins. There’s NACHA rules enforcement risk, but more than that, there’s a risk to your bank’s reputation as a service-oriented institution. However, some compliance considerations are out of your control; work through those with your ACH provider.

For example, if providers don’t take actions to prevent inadvertent same-day entries, your bank may end up originating same-day ACH entries, even if you don’t plan to do so. Take a proactive role and ask for the following:

tools to prevent or monitor stale-dated effective dates on file/batch submissions; and
the ability to track, count, and identify same-day ACH entries in a file/batch.

Same-day ACH transaction processing is a monumental step in moving payments faster. What your community bank does for this implementation sets the groundwork for future changes.

So come August when your community bank is testing same-day ACH functionality as you miss the kick-off meeting for your fantasy football draft, make sure your bank still chooses same-day ACH for your team. You want to set yourself up to win.


Sean Carter (scarter@neach.org) is senior vice president, payments strategies at the New England ACH Association, a regional member ACH-processing association in Burlington, Mass.