AFP has responded to NACHA’s request for comment (RFC) on expanding Same Day ACH. AFP supports the expansion overall, but made some recommendations for how it could best benefit corporate end-users.
NACHA has proposed raising the Same Day per-transaction limit from $25,000 to $100,000. AFP supports this measure, as it would expand the service to include a broader range of transactions. And as treasury professionals have already said repeatedly, the $25,000 threshold has kept many of them from adopting Same Day ACH.
NACHA is looking to add a third processing window that expands access to later in the day. AFP believes this measure would provide corporate treasurers with more flexibility when managing cash. Adding a new window would also make Same Day ACH more accessible for corporates operating in the Pacific Time Zone; this has been a challenge to due to the three-hour time difference.
NACHA’s proposal to provide faster funds availability to receivers of both Same Day and non-Same Day ACH credits also received AFP’s support. Faster funds availability would add speed and flexibility to corporate end-users of both Same Day and legacy ACH.
AFP also supports exploring ACH processing on weekends and holidays, however, it noted that there may not be a great need for additional B2B ACH payments processing. Generally, mass ACH payments are previously scheduled transactions and are not time sensitive.
AFP noted that faster payments result in faster fraud—and increasing the dollar amount per transaction means exposing larger dollar amounts to fraud. Thus additional fraud protections may need to be developed.
AFP stressed that all legacy ACH pricing and products need to remain intact and available. Disrupting current systems could have a negative effect on the way corporate treasury professionals do business.
Lastly, AFP recommends that merchants have flexible ACH filters. If someone wants to shut off the second or third presentation window, they should be able to do so and collect the next day.
All in all, AFP sees the expansion as highly beneficial; the association simply encourages NACHA to be mindful of some of the risks and wants to make sure that corporate treasury professionals can continue to maintain the status quo of their ACH payments if they choose to do so.
“Overall this kind of extension of Same Day ACH should be welcome as it opens up the options for corporates,” said Magnus Carlsson, AFP's manager of treasury and payments.