Letter to Nacha Supporting the Definition of "Banking Day"

Dear Ms. Bondoc:

The American Bankers Association (ABA) appreciates the opportunity to comment on Nacha’s Request for Comment regarding the definition of "Banking Day" within the Nacha Operating Rules. ABA is the voice of the nation's banking industry, representing small, regional, and large banks that collectively support consumers, businesses, and government entities through the ACH Network.

ABA strongly supports the proposed change to modernize and clarify the definition of Banking Day. The proposal appropriately recognizes that the Rules should measure ACH obligations by an objective network-operating standard rather than by increasingly outdated concepts of whether a financial institution is physically open to the public. ABA believes this change will provide greater certainty, consistency, and operational fairness across the ACH Network, and we urge Nacha to adopt the proposal.

Bankers view a clear and uniform Banking Day definition as essential because the term establishes the governing clock for returns, Notifications of Change, reversals, pre-notification waiting periods, documentation requests, and other time-sensitive obligations. A definition tied more directly to ACH Operator availability and network operations will make those obligations easier to identify, administer, and explain.

Download the comment letter to read the full text.