U.S. businesses gained a same-day processing option for Automated Clearing House debits on September 15, 2017, extending a service that had already covered credits. For a supplier collecting invoices through ACH, the change makes the date inside its payment file particularly important. Under NACHA’s rules, an eligible entry with an old or invalid date can settle at the next available opportunity—including the same day. A file-date error can therefore become a collection-timing error. [S1][S2]
The 2017 limit is US$25,000 per same-day entry. International ACH transactions and automated enrollment entries are excluded. The two operator submission deadlines are 10:30 a.m. and 2:45 p.m. Eastern, for settlement at 1 p.m. and 5 p.m. Eastern respectively. These are network deadlines, not a promise that a business can send its bank a file at the last minute. NACHA tells originators to discuss submission and exception-resolution cutoffs with their financial institution. Receiving institutions must accept same-day entries, but offering customers a same-day origination service is optional. [S1][S2]
The field to inspect is the Effective Entry Date in the company/batch header: it states the banking day on which the originator intends settlement. The current banking day’s date, combined with arrival before the operator’s cutoff, identifies a same-day transaction. Treasury’s September 11 explanation says stale or invalid dates can also produce same-day settlement and its associated entry fee. A bookkeeper should check what the invoice system exports, not just when someone presses send. NACHA specifically calls on originating banks to develop procedures for holding entries that arrive in time for a same-day window when that is not what the customer wants. [S1][S2]
An unpaid invoice is not permission to debit a customer’s account. Treasury’s September 11 rulemaking describes existing NACHA provisions for proof of authorization of covered business-account debits. A receiving bank can request that proof; the originating bank can respond with an accurate authorization record or the originator’s contact information for authorization inquiries. Treasury is describing earlier rule changes here, not a new permission created by the September 15 rollout. For a supplier, that means checking the collection authorization as well as the file date. [S2]
The published Same Day Entry fee is 5.2 U.S. cents per transaction, paid by the originating financial institution to the receiving institution. That is an interbank charge, not a quoted price for a small-business customer. NACHA advises businesses to discuss whether the service is cost-effective with their bank. Ask for the customer price and the file cutoff together before changing the collection schedule. [S1][S2]
Source documents
- Same Day ACH: Moving Payments Faster (Phase 2)https://www.nacha.org/rules/same-day-ach-moving-payments-faster-phase-2
- Federal Government Participation in the Automated Clearing House — 82 FR 42597https://www.govinfo.gov/content/pkg/FR-2017-09-11/html/2017-19135.htm
