Letter to Nacha on the Proposal to Increase the Same Day ACH Dollar Limit to $10 million

Dear Ms. Bondoc:

On behalf of the American Bankers Association (ABA) and our member institutions, we appreciate the opportunity to comment on Nacha's proposal to increase the Same Day ACH (SDA) per-payment dollar limit from $1 million to $10 million, effective March 19, 2027.

We support this proposed rule change and believe it is a critical step in advancing the efficiency and competitiveness of the ACH Network. Our position is based on the following considerations:

1. Demonstrated Growth and Proven Impact

Since its inception in 2016, SDA has been used to process over 5.25 billion payments totaling $12.1 trillion. Annual volume has grown from 13 million payments in 2016 to an estimated 1.35 billion in 2025. This reflects a sustained demand for faster settlement options.

The last dollar limit increase from $100,000 to $1 million in 2022 produced immediate benefits:

• 30% increase in SDA payment volume within two months.
• 118% increase in SDA payment value during the same period

2. Expanded Use Cases and Economic Benefits

• Business-to-business payments for vendor and supply chain invoices.
• Tax remittances to government agencies.
• Cash concentration and liquidity management for large organizations.
• Insurance claim payments.
• Same-day reversals, preserving operational integrity for large-dollar transactions.

Nacha estimates that this change will make $7–8 trillion in additional ACH dollars eligible for Same Day ACH annually, significantly enhancing the network's utility.

3. Alignment With Other Payment Rails

• The Clearing House RTP® raised its per-payment limit to $10 million in June 2025.
• FedNow® announced an increase to $10 million effective November 2025.

Consistent limits across major payment platforms will reduce operational complexity, improve resiliency, and support businesses that rely on multiple systems. This change will improve customer experience across different payment rails.

4. Risk Management and Operational Readiness

Following the 2022 limit increase, Nacha’s survey found no increase in fraud attributable to the higher SDA limit. Financial institutions have successfully managed risk under the current framework, and upcoming fraud monitoring requirements will further strengthen safeguards.

Our membership offered different perspectives on whether this rule should be segmented regarding its applicability to debits versus credits or different treatment for consumer transactions as opposed to business transactions. Much of the risk associated with SDA transactions relates to debits, especially those received late in the day. But setting different transaction limits for credits and debits will require more complicated technical implementation and provide an inconsistent customer experience. This would also require a longer implementation period for most financial institutions.

A similar situation arises if consumer transactions are treated differently than commercial transactions. Consumer transactions are less likely to be very large transactions and there were discussions about keeping these transactions at the $1 million limit to mitigate risk. Like the discussion above, this would require a more complicated technical implementation and create inconsistent user experience.

ABA recommends that the rule changes be implemented as proposed with the proviso that the membership did not reach consensus on whether to address placing different transaction limits on debits and credits.

The proposed effective date of March 19, 2027, is not adequate because of the amount of work needed to implement this change. Banks need time to:

• Update systems and dollar threshold edits.
• Adjust liquidity management processes for settlement windows at 1:00 pm, 5:00 pm, and 6:00 pm ET.
• Communicate changes to clients and implement internal controls.

Additionally, there are two other Nacha rule changes that have the same effective date. The first would add an optional birthdate field to International ACH Transactions (IATs) and the second would recognize the possibility that the financial agency outside the U.S. is a non-traditional account-holding institution or agency. Adding a third rule change effective on that date will strain bank resources.

ABA recommends that the effective date for this rule change be September 2027.

We commend Nacha for its leadership in advancing faster payments and endorse this proposal. Increasing the SDA dollar limit to $10 million will deliver substantial benefits to businesses, consumers, and financial institutions, while maintaining the integrity and security of the ACH Network.

Thank you for considering our comments. Please contact us with any questions or for further discussion.

Sincerely,
Stephen Kenneally
Senior Vice President, Payments