In December 2013, the Federal Reserve Board proposed changes to the posting times for ACH debit transactions and check transactions. It also proposed principles for establishing future posting rules for same-day ACH services. On February 6, TCH filed a comment letter in response to this proposal. While TCH is generally supportive of the Federal Reserve Board’s efforts to update its posting rules to better align them with current clearing times and private sector practices, TCH noted that the proposed changes present possible risks to the current EPN settlement process as well as the potential for competitive disparity in the services offered by the Reserve Banks and private sector payment operators.