NACHA released a supplement to the 2020 Operating Rules that created the ACH Contact Registry Rule − a comprehensive ACH contact registry. Under this rule, all ACH financial institutions will be required to register contact information for their ACH operations and fraud and/or risk management areas. This contact information will be made available to other registered ACH financial institutions, Payment Associations, ACH Operators, and NACHA to use with ACH-related system outages, erroneous payments, duplicates, reversals, fraudulent payments, and any other use within this scope. Financial institutions will be required to update their registry information within 45 days of any change and must verify it on an annual basis. Those financial institutions that fail to register their contact information may be subject to a fine according to a class 2 rules violation. This ACH registry seeks to address the difficulty in locating and communicating with the proper contact of participating financial institutions especially when time is of the essence.
Financial institutions should have procedures in place to (1) determine the correct contact information that must be registered, (2) ensure that this information remains current, (3) and route inquiries internally.
This amendment to the Operating Rules is effective on July 1, 2020. This is also the date that registration will begin for financial institutions to submit their contact information, which must be completed by October 30, 2020. NACHA’s rule enforcement authority is effective on August 1, 2021. More information about the ACH Registry Rule can be found here.
This supplement also addressed the creation of the third, daily Same Day ACH processing window. This new window will allow Same Day ACH files to be submitted to the ACH Operators until 4:45 p.m. ET (1:45 p.m. PT). Receiving financial institutions will receive files from this third window by 5:30 p.m. ET (2:30 p.m. PT), with interbank settlement occurring at 6:00 p.m. ET (3:00 p.m. PT), and they will need to make funds available for credits processed in the new window by the end of their processing for that Settlement Date.
This new processing window was expected to be effective on September 18, 2020; however, final implementation of the rule was contingent upon changes to Federal Reserve services necessary to support the new window. To accommodate the Federal Reserve Board, the effective date has been extended until March 19, 2021. These changes have been incorporated in the 2020 Operating Rules.