Letter to NACHA on the Definition of Banking Day and Related Operational Topics

Dear Ms. Bondoc:

The American Bankers Association (ABA) appreciates the opportunity to comment on the Nacha Request for Information regarding the Definition of Banking Day under the Nacha Operating Rules. We share Nacha’s goal of maintaining an efficient, safe, and timely payment system.

After consultation with member institutions, ABA believes that the industry would benefit from a revised definition of Banking Day that would remove uncertainty as to whether Sunday or bank holidays could be included in the interpretation. A clear definition of Banking Day would ensure both ODFI and RDFI participants apply a consistent interpretation regarding Nacha Rules that refer to Banking Day.

ABA asks Nacha to consider the implementation costs of any future change to the definition when developing subsequent proposals.

Thank you for the opportunity to provide input regarding these Requests for Information. Should you have any questions, please contact Stephen Kenneally at [email protected].

Sincerely,

Stephen K. Kenneally
SVP, Payments
American Bankers Association