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TCH Files Comment Letter to NACHA Supporting Same-Day RFC

The Clearing House Association joined by the Consumer Bankers Association submitted a letter to NACHA supporting the Same-Day ACH request for comment, which would enhance the ACH system by instituting ubiquitous same day clearing and settlement capability for eligible credit and debit transactions and would establish a per-entry interbank fee that will enable receiving depository financial institutions (“RDFIs”) to recover their costs and provide a fair return on their required investments. TCH suggested improvements to the proposal including adopting a different indicator in the Batch Header Record to identify transactions for same day processing and settlement, rather than relying on the Effective Entry Date and encouraged NACHA to consider leveraging additional evening settlement windows as a future enhancement to the same day ACH capabilities  in light of the expanded operating hours of the Federal Reserve Banks’ National Net Settlement Service.