TCH submitted a comment letter to Nacha in response to a Request for Comment on a proposal for increases to the same-day ACH transaction limit. The proposal would increase the transaction limit in three stages: from $100K to $1MM on March 18, 2022; from $1MM to $10MM on March 17, 2023; and on March 15, 2024 the same-day ACH limit would be eliminated altogether. The proposal also would give Nacha the ability to “pause” the scheduled dates “for up to 6 months if operational, risk, or fraud issues arise”. The TCH Comment Letter supported the transaction limit increase to $1MM and stated that additional increases may be merited in the future, but should be proposed once the risks of higher value same-day ACH transactions, and high value debits that clear and settle in the new third same-day ACH window in particular, are well understood. TCH pointed out that when received in the new third window, the high value same-day ACH debits may impact financial institutions’ end-of-day account balance forecasting and funding. Unanticipated high value same-day ACH debits could create liquidity risks for smaller institutions if they have insufficient funds in the Federal Reserve account used or their ACH settlement, or insufficient access to intraday credit. In addition, large value same-day ACH transaction may also require institutions to modify their controls related to credit, operational, and fraud risk for both ACH origination and receipt. TCH encouraged Nacha to provide industry education about increases to the limit and present additional information to the industry about liquidity, credit, operational, and fraud risk before moving forward with a proposal to raise the limit beyond $1MM.

To read the full comment letter click here.