On September 15, 2017, the National Automated Clearing House Association1 (NACHA) implemented Phase 2 of the Same Day ACH (SDA) Rule, adding Debit entry processing.  SDA allows same day settlement for eligible ACH1 credit transactions and non-monetary transactions processed by the ACH Network. With SDA, you can send SDA transactions throughout the day. It allows for faster funds availability, reduced risk and opportunities for new payment options.

Same Day ACH is being introduced in three phases:

  • Phase 1:  September 23, 2016 – Introduction of SDA with Credit entry processing only
  • Phase 2:  September 15, 2017 – Adds Debit entry processing to SDA
  • Phase 3:  March 16, 2018 – SDA funds available in receiver’s account by 5:00 pm local time

With Phase 2, origination setups with Comerica may be automatically enabled for same day Debit origination for select services. Comerica customers received details on this through additional communications. 

  • Same-day payrolls – helps you pay hourly workers, provides flexibility for late and emergency payrolls and missed deadlines, and faster access for employees to their pay.
  • Expedited bill payments using for ACH Credits and Debits - enables you to make supplier payments on due dates, and provides faster crediting for late payments; examples include mortgage, utilities, credit cards, and others.
  • Business-to-Business payments – provides faster settlement of invoice payments between trading partners to accelerate the release of goods and includes remittance information with the payments.
  • Account-to-Account transfers – allows for faster movement of money among various accounts owned by a single organization or consumer.
What qualifies for Same Day ACH processing?
  • Domestic Credit and Debit transactions of $25,000 or less
  • Returned Items and Notifications of Change (NOCs)
  • Pre-notifications for future Credits and Debits
  • Zero-dollar transactions
  • Transactions sent prior to the SDA cut-off time

The following do not qualify for same-day processing:

  • Domestic transactions greater than $25,000
  • International ACH Transactions (IAT)

The US Treasury started receiving and originating Credits in August 2017 and Debits on September 15. This is beneficial for paying income, payroll, and other taxes.

What you need to know about using Same Day ACH

The following is important information you should know as a Same Day ACH Originator and Receiver, or both. For most applications, use of Same Day ACH functionality may be as simple as using today’s date in the Effective Entry Date field and submitting your file prior to the SDA cut-off.

When will Same Day ACH funds be available?
  • Effective with Phases 1 and 2, financial institutions are required to make qualifying Same Day ACH Credits (such as payroll Direct Deposits) available to Receivers by the end of the financial institutions’ processing day.
  • Effective with Phase 3, funds must be available by 5:00 pm local time.
If you receive ACH transactions
  • Comerica has reporting options available to help you comply with applying funds to your systems according to NACHA requirements for ACH activity – intra-day, end-of-day, and next-day. Some of the reports include the Settlement Date to assist you with your accounts receivables processing.
    • If you want to add intra-day or end-of-day reporting for your ACH addenda activity, please contact your Treasury Management representative.
    • If you are using next-day reporting, you may need to adjust your funds application processes to use the Settlement Date to apply funds, as multiple Settlement Dates may be contained in your report or file. Engage your IT team and/or IT vendor as necessary. 
  • Review your processes for applying funds and determine if you are using the Effective Date or Settlement Date to apply funds. If you are using the Effective Date, you will need to use the Settlement Date instead.
  • Contact your Treasury Management representative to discuss the ACH reporting option that compliments your processing environment.
Same Day ACH – Debits

Information for Receivers

  • According to NACHA Rules, your client records must reflect a date that is no sooner than the Settlement Date for Debits.  This means that same-day activity included in reporting may need to be back-dated to reflect proper same-day and next day posting within your receivables system.
  • Because all financial institutions are required to receive Same Day ACH transactions, you can be confident that qualifying transactions will be credited to your account the same day and debited from your account the same day.
  • ACH Positive Pay can allow you to decision transactions to post to your account on the day received or held for your review the next day.
If you originate ACH transactions

Know when you want your Receiver to be charged

  • Be sure you provide an Effective Date that is really when you want the Receiver to be debited, so that you receive funds on the agreed upon date you are scheduled to be paid.  Charging your Receiver prior to the agreed upon date could result in a transaction being returned as unauthorized.  For example, if you need to receive payment tomorrow, use tomorrow as the Effective Date on the file you send to Comerica today; if you need to receive payment today, use today as the Effective Date.
  • Credit reversals qualify for SDA.  Note that a reversal cannot be made prior to the Settlement Date of the original transaction.
  • Also be aware of the time you submit your ACH transactions so that you transmit prior to same day and end-of-day processing deadlines.
  • Qualified ACH originations with a current, stale, or invalid Effective Date may be processed as SDAs.
  • You may be using a same day Effective Date on some of your ACH batches.  As such, your transactions may qualify for SDA.  Please be sure to use a same day Effective Date only with transactions you intend to be credited or debited same day.

Information for Originators

  • When sending ACH transactions, managing the Effective Date in your origination file is critical.  Comerica settles all valid transactions on the earliest available Settlement Date.  As a result, qualifying ACH transactions submitted before the SDA deadline will settle and be billed as same-day transactions. 
    • Therefore, it is vital that your Effective Date and batch submission time reflect a date that is no earlier than the date agreed upon by your Receiver.
  • Only qualified SDA debit batches will be credited to your account same day.  All other batches will be settled on the earliest available Settlement Date. 
  • Do not mix qualified and unqualified SDA transactions in the same batch, as it may result in split settlements.
  • With NACHA’s Same Day ACH rule, a current day or a stale date in the Effective Date field triggers same-day processing, if all other requirements defined in the SDA rule are met. Therefore, be sure you are not originating ACH transactions for same day settlement unintentionally.
  • You can submit files of Same Day ACH transactions throughout the day.  Qualified SDA transactions will be settled same day as long as they are received before the deadline.
Same Day ACH – Credits

Know when you want your Receiver to be paid

  • Be sure you provide an Effective Date that is really when you want the Receiver to be paid, so that you pay them on the date they are scheduled to be paid.  For example, if you need to pay your vendor tomorrow, use tomorrow as the Effective Date on the file you send to Comerica today; if they need to receive payment today, use today as the Effective Date.
  • Also be aware of the time you submit your ACH transactions so that you transmit prior to same day and end-of-day processing deadlines.
  • ACH originations with a current, stale, or invalid Effective Date may be processed as SDAs.
  • You may be using a same day Effective Date on some of your ACH batches. As such, your transactions may qualify for SDA.  Please be sure to use a same day Effective Date only with transactions you intend to be credited or debited same day.

Information for Originators

  • When sending ACH transactions, managing the Effective Date in your origination file will be critical. Comerica settles all valid transactions on the earliest available Settlement Date. As a result, qualifying ACH transactions submitted before the SDA deadline will settle and be billed as same-day transactions.
    • Therefore, it is vital that your Effective Date and batch submission time correlate with when you want the Receiver to be paid and that you ensure sufficient funds are available for same-day settlement.
  • With NACHA’s Same Day ACH rule, a current day or a stale date in the Effective Date field triggers same-day processing, if all other requirements defined in the SDA rule are met. Therefore, be sure you are not originating ACH transactions for same day settlement when you do not intend to.
  • Do not mix qualified and unqualified SDA transactions in the same batch, as it may result in split settlements.
  • Originators can submit files of Same Day ACH payments throughout the day and payments will be settled same day, as long as your qualified Same Day ACH transactions are received before the deadline.
What your IT or vendors may need to know
  • You may need to engage your IT team or vendor for programming and/or to adjust processes for you in preparation for SDA. We recommend that you contact them to be sure they are aware of what you may need for Same Day ACH and that your programs apply Credits and Debits for same day settlement when you intend.
  • Click here to learn more about Same Day ACH at NACHA.org.

1 The Automated Clearing House and NACHA are not affiliated with Comerica Bank.