With the addition of the third same day ACH window effective March 19, 2021, many banks are pushing back the times they are starting their updates to move the core system into the next processing day to ensure they are in compliance with NACHA rule 18.104.22.168 – Availability of ACH credits that are same day.
When changing your end of day update times, there are a few things you will want to keep in mind.
First, will you be changing your mobile deposit/remote deposit cut off times? Will you be changing your teller window banking cut off times? If your answer is yes to either of these, make sure you inform your processor. IDS On-Time asks that you let us know in advance if you are changing your cut off times. We like to give our financial institutions at least 15 minutes to allow the staff to balance and cut over to the next day without us getting in the way. For mobile and remote deposit cut off times, we recommend giving your staff at least 30 minutes before we start your end of day to verify and approve all the incoming deposits. If you need more time, simply call us, and we can hold your end of day processing for an hour or so until you have balanced or until you are able to verify all your deposits.
The second thing to consider is your cut off times for business customers to originate ACH files. Will you expand the time to originate ACH files or keep it the same? If you do expand, will there be staff there to approve the files in a timely manner? Keep in mind if an ACH file is effective next day and does not get approved until next morning, you will be charged the extra 5.2 cents for a same day file. Also, did you let your processor know they need to be looking for this extra window for ACH files?
Lastly, the question I get asked quite often as a processor by our banks is, “Do we need to update our disclosures?” I encourage you to talk to your compliance team or your Regional Payment Association, as they are better equipped to answer this question. However, keep in mind Reg CC subsection B does cover availability of funds. If there is an adverse change which effects the consumer, you have to provide them notification 30 days in advance of the charge. If the charge does not adversely affect the consumer, then the bank can provide notification up to 30 days after the change.
Keep these things in mind when you are looking at changing your end of day update times, and things should run smoothly for you come March 19th.
About Automated Systems, Inc.
Since 1981, Automated Systems, Inc. has been a leader in providing innovative core banking, digital banking, and data processing solutions to community banks nationwide. An array of integrated applications provide partnered banks with tailored, cost-effective, competitive choices. ASI delivers industry-leading technology backed by unparalleled in-house conversion, training and support teams; paving the way for progressive, top-notch customer service. ASI corporate headquarters are located at 1201 Libra Drive, Lincoln, NE 68512, 1.800.279.7312. For more information about banking solutions from ASI, visit www.asiweb.com.
About Insite Data Services
IDS data application hosting services combines secure and cost-effective core banking applications, enterprise-class servers and storage, and proven virtualization technology. IDS hosts all of the bank’s servers in secure data centers that use state of the art security systems including identity verification and biometric scanning. Insite Data Services also offers IDS On-Time, a full-service solution dedicated to back-office bank processing. These operations experts allow partnered banks to focus on their most important asset, their customers. For more information visit www.insitedataservices.com.