The Independent Community Bankers of America (ICBA) has expressed conditional support for several of Nacha’s proposed amendments to the Automated Clearing House (ACH) operating rules, emphasizing the need for balanced implementation while considering operational risks and fraud prevention.
Nacha, formerly known as the National Automated Clearing House Association, is the organization responsible for managing, developing, and enforcing the rules that govern the ACH network in the U.S.
The ACH network was created to enable the electronic transfer of money between bank accounts, supporting transactions such as direct deposits, bill payments, business-to-business payments and government disbursements.
ICBA endorsed the Bureau of the Fiscal Service’s proposal to adopt Nacha rule amendments from 2022 through 2024. The trade group asserted that doing so would create efficiency by requiring the public and private sectors to adhere to a unified set of ACH operating rules.
The organization also supported the adoption of the 2024 risk-management supplement, noting its recent implementation in the private sector, but noted concerns over the quality of data provided in the ACH Contract Registry and the timeliness of updates.
“The ACH Contact Registry is available to nearly all members in the ACH ecosystem, from the participating financial institutions to payment associations and ACH operators,” the ICBA wrote in its comment letter. “The contact information is password protected for bank-to-bank use. Currently there are two mandatory contacts: ACH operations and Fraud/Risk Management. The accuracy of contact information is audited during the annual ACH audits and Nacha has stated that it will increase the number of random audits within its auditing process.”
ICBA opposed the addition of a fourth Same Day ACH (SDA) processing window, citing increased settlement risks, particularly over weekends, and the potential for heightened exposure to credit-push fraud. The organization also expressed concerns about the proposal to accelerate funds availability for non-SDA credits, arguing that mandatory early availability could compromise fraud detection efforts and impose undue operational challenges on community banks.
ICBA recommended delaying the implementation of both the fourth SDA window and the accelerated funds availability proposal. They suggested a minimum of 24 months between the rollout of new ACH credit monitoring requirements and the introduction of these changes to allow adequate time for adjustment and evaluation.
“ICBA supports making payments faster, more convenient, and proving faster availability of funds,” ICBA wrote. “However, ICBA opposes expanding IATs (International ACH Transaction) to SDA availability. The benefits of enabling SDA for the domestic leg of IATs comes with significant operational effort and risk. While ICBA does not object to making an IAT contact mandatory in the ACH directory, it urges Nacha to continue conducting random audits to ensure timely responses from listed contacts.”