According to Nacha, this fourth SDA window would correlate with the close of the business day in the Pacific Time Zone. Morris said this change would significantly impact large and small credit unions with “costly technical changes to account for the late receipt of large debits or ending a day in a net-debit position, which would add complexity to their operating environments.”

Morris added, “To adjust to the proposed SDA window, credit unions would need to allocate additional staff to monitor fraud and ensure sufficient funding well past the normal close of business if located in eastern time zones. America’s Credit Unions is concerned that fraudulent transactions submitted during a fourth SDA window will stress internal review resources late in the day, particularly on Fridays, which would necessitate providing nearly immediate funds availability despite delayed settlement when the National Settlement Service reopens. Recent surveys suggest that fraud involving ACH credits has grown since 2019. The vigilance required to deter fraud across all payment channels continues to impose a high burden on all credit unions, but particularly for the smallest who may rely on manual processes for detecting anomalous transactions. Requiring RDFIs to stretch their resources across a longer operating day to facilitate SDA expansion could frustrate efforts to efficiently manage risk.”

Additionally, Nacha proposed accelerating funds availability for certain non-SDA credits. “America’s Credit Unions has concerns that the operational impact to credit unions will outweigh the benefit of this rule change, particularly when the exact timing of non-SDA funds availability is largely determined by the ODFI,” the organization said in a statement.

“Given the availability of real time settlement systems, which can achieve many of the same benefits targeted by the proposed SDA expansion, Nacha should reconsider its proposal,” Morris wrote.