In December 2020, Nacha issued a Request For Comment for a proposal to increase the Same Day ACH dollar limit on a schedule of three increases over three consecutive years. By the third increase, the Same Day ACH dollar limit would have been eliminated. The increases would apply to all Same Day ACH payments; Consumer and business payments, credits and debits
The proposal would have given Nacha the ability to pause the scheduled effective dates for up to 6 months if operational, risk, or fraud issues arise. A 60-day notice would be given in the event of a pause.
Responses to the RFC:
107 responses were received to the RFC, including 68 financial institutions. FI respondents were well distributed among asset sizes
91% of respondents agreed that the current Same Day ACH dollar limit should be raised
85% agreed that all Same Day ACH entries should have the same limit
60% said new/expanded use cases would be created by raising the dollar limit, such as:
53% of respondents indicated a higher dollar limit would increase or significantly increase their usage of Same Day ACH
82% said impacts to their ACH operations and technology would be minimal-to-moderate
Respondents rated the impact on risk management as somewhat more impactful, though 60% still rated it as minimal-to-moderate
71% of all respondents agreed that Same Day ACH payments should ultimately have the same limits as non-same day payments.
Nearly 70% of respondents supported raising the dollar limit in multiple scheduled increases.
Many respondents supported an increase to $1 million per eligible entry, but not subsequent increases without re-evaluation
Many respondents commented in support of an increase in March 2022, but not scheduled future increases
Changes from the original proposal in the RFC:
This rule provides for a single increase of the limit to $1 million per entry, instead of three increases over three years
- A sufficient percentage of respondents provided feedback and commentary that a single, incremental increase creates value for users of Same Day ACH, but that future increase should be deliberated after evaluation of this initial increase
- Without multiple, future increases, there is not a need to provide for the ability to pause the schedule