New York Credit Union Association

Originating Depository Financial Institutions (ODFIs) frequently file or send ACH payments to Receiving Depository Financial Institutions (RDFIs) prior to the day they want the credit to be made available to a consumer. For example, a company might instruct its payroll processor to send direct deposit salary payments to their employee’s banks a day or two before the actual pay day. By sending files earlier than the day the funds are to be made available, the ODFI could potentially recall payments sent in error. Increasingly, however, many RDFIs are making ACH payments available when they are received. Under the existing NACHA rules, an ODFI basically guarantees to an institution it sends money to that it will be able to honor its NACHA credits. Consequently, there is no penalty imposed on institutions which prematurely make ACH payments available to consumers.

Against this backdrop, NACHA is considering proposing a rule to make institutions that make funds available before the date specified by an ODFI be responsible for any harm resulting from a premature payment.

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* 1. Your Full Name

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* 2. Credit Union Name

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* 3. Does your credit union make ACH payments available prior to the date specified by the ODFI that sent the file?