In response to NACHA’s Expedited Processing and Settlement Proposal, TCH Payments Company submitted a comment letter suggesting that the costs and benefits of same day ACH settlement need to be balanced among all ACH participants. In particular, the proposal needs to provide a business case that enables participants to recover the significant costs that will be incurred to enable same day settlement as well as future core ACH improvements. The Payments Company also thinks that (i) default settlement should remain next day, (ii) same day entries should be identified in manner that enables them to be readily recognized, (iii) a $25,000 dollar cap should apply to same day entries and be enforced by operator edit or the ability to return over the limit entries, and (iv) industry participants will need 18 to 24 months to implement same day settlement.