How to Handle ACH Processing Delays Due to Severe Weather
With hurricane and storm season here, we want to remind you of the Excused Delay provision of the Nacha Operating Rules (Section 1.5). This is a reminder of the steps that you should take if your ACH entries or returns processing is affected.
If you use an outside party to process files, contact them immediately to let them know of your situation. Typical sending/receiving points include: Correspondent Banks, Corporate Credit Unions, Banker’s Banks or Processors. ACH files should remain available to you for several days (typically up to 10). Please contact the Check and ACH department at the Federal Reserve Bank (877) 372-2457 if you need a remake.
Debits and credits will continue to post to your Federal Reserve account as normal. Make sure you have funds available to cover normal activity.
The Federal Reserve is available to assist in any way possible. The Federal Reserve Sales support line is (800) 257-6701.
Nacha Operating Rules include a provision for Excused Delay that applies to processing delays caused by an interruption of communications or computer facilities that is out of the control of the financial institution, due to an act of God (i.e., weather emergencies) or war. This rule is not intended to excuse delays due to general failure of a financial institution's computer system or other equipment as that should be addressed in financial institution’s contingency planning procedures.
If your institution’s ability to process ACH transactions is impacted, Macha recommends that once your system is operational, you originate your return transactions as you normally would. It is very likely that some entries will be returned as untimely primarily due to automated return systems. If you receive these returns from the ODFI as dishonored returns with the Return Reason Code R68, Untimely Return, then you should contest the Dishonored Return using code R73, Timely Original Return. If the ODFI contacts you for clarification, you should explain that you are using the Excused Delay provision of the ACH Operating Rules.
You may choose to call the ODFI before sending the original return, but are not obligated under the ACH Rules to do so.
Be aware that some ODFIs may not handle the Contested Dishonored Return correctly and may dishonor it again. This is not allowed under the ACH Operating Rules, and you should contact the ODFI directly or contact Macha within the twenty-four-hour return deadline timeframe for assistance if this happens to you.
While there is no "official or approved" excused delay list, the Federal Reserve does publish a list of institutions that have contacted the Fed regarding their contingency situation. Again, this is not an official list but many of the larger financial institutions "use" the list as such.
If you or your staff have additional questions, please reach out to our helpful staff here at Macha!
Toll Free: 800-453-1843