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Effective March 16 2018, phase 3 of Same Day ACH which modifies memo posting times goes into effect.
What do I need to do:
- Familiarize yourself with the rules around Same Day ACH.
- Have discussions with trading partners who may wish to send or receive Same Day ACH
- Plan for how your banking services may be impacted by Same Day ACH
Overview of Same Day ACH:
Per the Rule, Same Day ACH will be rolled out in three separate phases.
Phase 1 - September 2016 (credits only). All Financial Institutions are required to receive and settle qualified Same Day ACH credit items by the end of business on that same day.
- Phase 2 - September 2017 (credits and debits). All Financial Institutions are required to receive and settle both ACH credits and debits by the end of business on that same day.
- Phase 3 - March 2018 (funds availability). All Financial Institutions are required to make Same Day ACH funds available to the payee from Same Day ACH credits (such as payroll Direct Deposits), to their depositors by 5:00 pm at the Receiving Depository Financial Institution's (RDFI) local time.
While most transactions are eligible for Same Day ACH, there are some exclusions:
- Transactions over $25,000
- IATs (International ACH Transactions)
- ENRs (Automated Enrollments)
All banks must receive Same Day ACH transactions. Banks may elect when, how and with what limitations to offer Same Day ACH origination.
How are my Treasury Management Services affected?
How does Same Day ACH impact my Electronic Data Interchange (EDI) reporting?
EDI reporting for Same Day ACH transactions received into your account is provided on a next business day basis. You are still responsible for applying customer payments on the days funds are received.
How does Same Day ACH impact my ACH Positive Pay service?
ACH Positive Pay is not impacted by Same Day ACH. Same Day ACH transactions are screened in the same manner as other ACH transactions. Exceptions are presented at the same time and in the same manner as other ACH exceptions. The deadline for making a pay or return decision on these exceptions is the same as other ACH exceptions.
When will Same Day ACH transactions post to Business Online Banking? How will this impact my cash forecasting and reconciliation?
Effective March 16, 2018, Same Day ACH transactions will show as pending in your account by 5:00 pm ET. Other ACH transactions will continue to be received by the bank and memo posted to your account in the morning.
All ACH transactions for the day impact the available balance in your account and should be factored into your overall cash forecast for the day. You may wish to contact customers who pay you electronically, to determine if they expect to pay you via Same Day ACH. If they do, it may be helpful to discuss the parameters for payment notification (i.e. if, when and how you will be notified).
You may wish to have similar conversations with vendors who collect payment from you electronically. Debit items could post to your account the same day they are authorized. To avoid overdrafts funds should be in your account before you authorize any payments.
Our Line of Credit Sweep and Zero Balance Account services calculate your cash position and transfer funds on your behalf. Both services will factor in Same Day ACH transactions when making those calculations and transfers. If you do not have these services and wish to learn more, please contact your Treasury Management representative.
How does Same Day ACH impact my Line of Credit Sweep service?
Line of Credit Sweep is not impacted by Same Day ACH. Our Line of Credit Sweep service factors in Same Day ACH transactions when calculating the Line of Credit Sweep transaction amount.
How does Same Day ACH impact my Zero Balance Account service?
Zero Balance Account transactions are not impacted by Same Day ACH. Our Zero Balance Account service factors in Same Day ACH transactions when calculating the Zero Balance Account transaction amount.
How does Same Day ACH impact my ACH Origination services (template ACH)?
Same Day ACH does not impact any template originated ACH transactions. These transactions continue to be exclusively next day/ future dated transactions. Template transactions are initiated using the Payroll, Cash Disbursements, Collections, Cash Concentration, EFTPS Tax Payment or Child Support apps within Business Online Banking. (This applies whether you import data or hand key transactions).
How does Same Day ACH impact my ACH Origination services (send file or direct transmission ACH)?
Same Day ACH directly impacts all send file and direct transmission ACH. Files (including pre-note files) may not contain an Effective Entry Date which qualifies for Same Day ACH without prior agreement with the Bank. Please ensure you have the proper controls in place to prevent inadvertent creation and transmission of a Same Day ACH file.
Any future updates or changes to your software should also be reviewed for compliance with the Effective Entry Date requirements.
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