The Clearing House submitted a comment letter in response to Nacha's (i) request for information on the definition of "Banking Day," (ii) request for comment on proposed changes to ACH return timeframes ("return efficiencies"), and (iii) request for information on the timeframes for dishonored and contested or corrected dishonored returns.

The letter expresses support for revising the current definition of “Banking Day” under the Nacha Operating Rules ("Nacha Rules") to promote greater clarity, consistency, and predictability in the application of the Nacha Rules and related deadlines across the ACH network. The letter also conveys member feedback regarding Nacha’s proposal to shorten certain ACH return timeframes, noting concerns about the operational, technical, and implementation impacts of the proposed changes and concluding that the anticipated benefits do not justify the associated burdens. Lastly, the comment letter recommends retaining the current timeframes for dishonored returns and contested or corrected dishonored returns, concluding that the existing deadlines remain necessary to support appropriate investigation, customer communication, and decision-making. To read the full letter, click here.