Helpful Tips for New Same Day ACH Rules
Helpful Tips for New Same Day ACH Rules
Since NACHA’s same day ACH Phase 1 is currently in effect (since September 23, 2016) here are some helpful tips to ensure same day ACH processing is performed smoothly throughout the remaining two phases (September 15, 2017 and March 16, 2018) for both RDFIs and ODFIs:
- ODFIs can determine whom they would like to allow same day ACH originations to (i.e. businesses only, consumers only, etc).
- Ensure proper use of effective entry dates is utilized to properly identify if the ACH is same day or a next day effective date.
- Ensure contracts, procedures, Terms & Conditions agreements, and fee schedules are updated appropriately based on same day ACH fees and processing times.
- Ensure TEL transactions include the proper notices prior to settlement for same day single entry ACH and same day recurring TEL transactions.
- Ensure ARC, BOC & POP disclosures accurately reflect proper verbiage “that the check would be converted to ACH debit and could possibly post as soon as the same day” once Phase 2 is in effect.
- Properly identify when NSF fees will be assessed under Phase 2 (either at both settlement times or once during the day) and accurately reflect this information on fee schedules provided to borrowers.
- Be consistent when charging NSF fees related to same day ACH transactions.
Now that you have these helpful tips in your pocket are you ready for Phase 2?
For additional questions please contact the author Natalie at nyerger@fosaudit.com.
Helpful Tips for New Same Day ACH Rules