Nacha Increasing the Same Day ACH Dollar Limit to $1 Million

1/31/2022 - By Janice Weisz, AAP

The Nacha Rules continue to expand the capabilities of Same Day ACH. Effective March 18, 2022, the Nacha Rules will increase the Same Day ACH per-transaction dollar limit from $100,000 to $1,000,000. This new limit will apply to all eligible Same Day ACH payments, including credits and debits for both businesses and consumers. The $1 million limit will be beneficial for many types of payments, i.e., insurance claim payments, payroll funding, business-to-business payments, tax payments and many more.

Effective Date

The Rule becomes effective on March 18, 2022.

Impact to Participants

Originators and Third-Party Senders

Originators and third-party senders should discuss with their financial institutions whether and when originating debit and/or credit entries up to $1,000,000 is appropriate for their business. If these participants choose to transmit such entries, they need to be prepared for higher dollar transactions flowing through their accounts multiple times during the business day.

ODFIs

ODFIs need to determine whether and how they will implement higher-limit same day transactions with their originator and third-party sender customers. Higher Same Day ACH dollar limits might impact a financial institution’s assessment of its customers’ credit risks. ODFIs that offer Same Day ACH will need to update internal processing applications and procedures to accommodate higher dollar limit same-day entries.

RDFIs

RDFIs may need to update their internal processing applications and procedures to accommodate higher limit same-day entries. RDFIs should be prepared for a larger amount of dollars settling at several times throughout the day.

Receivers

Receivers, particularly non-consumer receivers, should be prepared to receive ACH debits and credits up to the new $1,000,000 limit. Receivers need to be ready for the possibility of higher dollar transactions posting to their accounts throughout the business day. Receivers should review their internal procedures to determine whether any changes are required.

For more information, you can also visit Nacha's website.

Staying in compliance can be challenging, if you have any questions or need assistance preparing for these new Nacha Rules, email me or a member of our Financial Institutions Team so we can help.

About the Author | Janice Weisz, AAP

Janice is a consultant in the Financial Institution Advisory Group at Saltmarsh, Cleaveland & Gund. Janice has been working with financial institutions since 2001 with an emphasis on operations, compliance, audit and internal controls. Janice currently is an Accredited ACH Professional (AAP) and conducts risk-based Nacha compliance audits and provides ACH-consulting services to the firm’s financial institution industry clients.