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NACHA Rules Changes
January – ACH Rules Compliance Audit Requirements Consolidated in Article One
Previously the general obligation for participating DFIs (Depository Financial Institutions) and certain Third-Party Service Providers (TPSPs) and Third-Party Senders (TPSs) to conduct an audit was within Article One, Section 1.2.2. and the details pertaining to the audit obligations were located within Appendix Eight (Rule Compliance Audit Requirements) of the Rules. Effective January 1, 2019, the requirement to conduct an annual compliance audit is consolidated within Article One of the Rules. The prescribed list of topics that had been in Appendix Eight previously in the Rules is now part of the Guidelines as guidance.
June – RDFIs (Receiving Depository Financial Institutions) have Option to Return for Questionable Transaction
Effective June 21, 2019, this change allows RDFIs, but it is not required of RDFIs, to indicate within a return that the original transaction was questionable or part of anomalous activity. RDFIs electing to return under this circumstance would use R17 as the return reason code and would indicate “QUESTIONABLE” in the Addenda information field.
September – Providing Faster Funds Availability for Same Day and Next Day ACH Credits
Effective September 20, 2019, this new rule increases the speed of funds availability for certain Same Day ACH and next-day ACH credits. There are two changes with this rule, first, funds from Same Day ACH credits processed in the existing, first processing window will be made available to receivers by 1:30 p.m. RDFI local time. Secondly, funds from non-Same Day ACH credits will be available by 9:00 a.m. RDFI local time on the settlement day, if the RDFI had them by 5:00 p.m. on the previous day. This applies the existing “PPD rule” to all ACH credits.
Coming in 2020
March – Same Day ACH per Transaction Increases to $100,000
Effective on March 20, 2020, the per-transaction dollar limit for Same Day ACH transactions will increase from $25,000 to $100,000. Both Same Day ACH credits and Same Day ACH debits will be eligible for same day processing up to $100,000 per transaction.
June – Supplementing Data Security Requirements for Large Originators, Third-Party Service Providers (TPSPs) and Third-Party Senders (TPSs)
Effective on June 30, 2020, this change to the Rules is intended to enhance quality and improve risk management within the ACH Network by supplementing the existing account information security requirements for large-volume Originators and Third-Parties. Participants are required to protect deposit account information collected for or used in creating ACH transactions by rendering it unreadable when it is stored electronically.
This change will be implemented in two phases:
- The rule initially applies to ACH originators, TPSPs and TPSs with ACH volume of 6 million transactions or greater annually. An ACH originator, TPSP or TPS that originated 6 million or more ACH transactions in calendar year 2019 would need to be compliant by June 30, 2020.
- The second phase would apply to ACH originators, TPSPs and TPSs with ACH volume of 2 million transactions or greater annually in the 2020 calendar year and compliance is required by June 30, 2021.
Coming in 2021
March - Supplementing Fraud Detection Standards for WEB Debits
Effective on March 19, 2021, the rule change is intended to enhance quality and improve risk management within the ACH Network by supplementing the fraud detection standard for Internet-initiated (WEB) debits. ACH originators of WEB debit entries have always been required to use a “commercially reasonable fraudulent transaction detection system” to screen WEB debits for fraud. The existing screening requirement is supplemented by this change to make it explicit that “account validation” is part of a “commercially reasonable fraudulent detection system”. The supplement requirement would apply to the first use of an account number or changes to the existing account.
March – Expanding Same Day ACH to Later Deadline
The effective date of a new, third Same Day ACH processing window is March 19, 2021. RDFIs must make funds available for SDA credits in this new SDA processing window no later than the end of its processing day.
Previously Published NACHA Rules Updates
Effective March 16, 2019, the final phase of the initial Same Day ACH implements the rule that funds availability for Same Day ACH credits is by 5:00 p.m. local time of the receiving financial institution.
Important Legal Disclosures & Information
Bank deposit, treasury management and lending products and services, and investment and wealth management, and fiduciary services are provided by PNC Bank, National Association, a wholly-owned subsidiary of PNC and Member FDIC. Lending and leasing products and services, including card services and merchant services, as well as certain other banking products and services, may require credit approval.
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