NACHA RULES UPDATES 2019 – 2021

Below are selected Operating Rules changes published by NACHA – The Electronic Payments Association®. The effective date for each Rule update is provided along with a summary of the change.

The complete set of annual ACH Operating Rules and Guidelines is available for purchase from NACHA at https://www.NACHA.org. Purchase of this printed material also allows online access to the Rules. Alternatively, you may visit http://www.achrulesonline.org/ to view options for free and paid online-only access.

If you have questions, please feel free to contact your local Treasury Management Officer or Treasury Management Services Support at 1-866-475-7262.

Effective June 21, 2019

Expanded Use of Return Code R17/ Return for Questionable Transaction

  • This upcoming Rule will expand the use of the existing return reason code R17 to allow the receiving financial institution to use this code to indicate they believed the entry was initiated under questionable circumstances.
  • Using R17 for this purpose would require the use of the description "Questionable" in the Addenda Information field of the return to the Originating Bank and ultimately the Originator.
  • This return code selection is optional, and at the discretion of the financial institution returning the entry.
  • Potentially useful for a grouping of initiated items, that may seem questionable in nature.
Effective Sept 20, 2019

Providing Faster Funds Availability for ACH Entries at Receiving Banks

  • Same Day Credits: Receiving depository financial institutions must provide an additional memo post by 1:30 p.m. local time all Same Day ACH credits provided by the ACH Operator each business day.
    • This change results in the posting of Same Day ACH credits twice per business day, one by 1:30 p.m. and the second by 5:00 p.m. local time.
  • Next Business Day Credits: Receiving depository financial institutions must make funds available by 9 a.m. local time for all ACH credits received by the ACH Operator by 5 p.m. local time the preceding business day.
    • This change expands the current requirements from business to consumer (PPD) credits to include all Standard Entry Class (SEC) types.

Note: TD Bank ACH originators and receivers will not notice a change in the timing of receipt of ACH credits because TD Bank already meets these requirements. However, receivers of your originated entries at other banks may notice faster availability.

Effective March 20, 2020

Dollar limit increase for Same Day ACH entries initiated

  • This rule increases the Same Day ACH Dollar limit for all Same Day eligible items (both debit and credit) from $25,000 per item to $100,000 per item.
Effective March 19, 2021

Account validation requirement for WEB initiated debits

  • WEB (Internet Initiated ACH Payments) will specifically require an additional "account validation" screening as part of a "commercially reasonable fraudulent transaction detection system."
    • The supplemental requirement would apply to the first use of an account number, and changes to an account number previously used.
    • The requirement is non-specific with regard to the method or technology to validate account information.
  • Customers who create WEB transactions using their own software, or with that of software provider or other vendor must ensure this validation is in place on or before the effective date.
  • If your organization originates WEB entries, please take action now to ensure you'll have account validation functionality in place before this change becomes effective.
    • Please see NACHA.org for suggestions or contact your Treasury Management Sales Officer for more details.

Note: Customers that use TD Bank's TD eBill service to originate WEB transactions will be compliant with this requirement by the effective date.

Effective March 19, 2021 – Newly Proposed Implementation Date

Expanding access to Same Day ACH later in the business day

  • This new Rule extends the delivery deadline of Same Day ACH items into the ACH network by 2 hours each business day, by creating a third Same Day ACH window to the ACH Operators.
  • There will be no new intraday memo post requirement by the receiving bank, as the item must post to the account as of the end of day of the effective entry date.
  • This Rule change implementation is contingent upon timely notification by The Federal Reserve Board of Governors of changes to Federal Reserve services necessary to support the extension.