The proposed change would enable most ACH transactions to be processed on the same-day. ABA supports innovations to the payments system as long as the integrity of the system remains intact, consumers are protected and participants in the system are regulated similarly. In the comment letter, ABA addressed each of the proposed modifications:
Moreover, ABA stresses that in the Interbank Compensation Framework (ICF) it supports the interbank compensation fee model as a method to help receiving depository financial institutions absorb at least a portion of the costs of implementing and maintaining same-day ACH functionality.
In what concerns the Phased in Approach (PA) ABA supports it because it enables financial institutions to plan their system upgrades over a period of almost three years. As to Abbreviated Processing Times (APT) ABA recommends that the deadline for granting ACH credit to customers be changed from 5 p.m. local time to 6 p.m. local time.
Lastly, for Identification of Same-Day ACH Items (ISDA) ABA supports the utilization of an existing field to identify same-day transactions, but it could prove troublesome. A better choice would be to clearly to identify same-day ACH transactions through the use of a new Service Class Code located in the Batch Header Record.
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