If an ACH unposts and we decide to post the transaction to the customer's account, shouldn't we post the ACH as of the effective date and not the current posting date?

If so, where can I find this in the NACHA guidelines?

Bump

NACHA rules require ACH credits be made available to the receiving customer no later than the settlement date of the ACH entry. Posting the entry to the customer's account earlier is allowed by NACHA, but creates a risk to the bank if final settlement from the originating bank doesn't occur. NACHA rules state that ACH debits can not be posted any earlier than the settlement date. Posting later is allowed by NACHA, but creates a extension of credit situation for the bank since it must settle the entries on the settlement date (i.e. - bank must remit the money for the debit entry on the settlement date, but didn't yet collect from the customer's account).

What about the ACH transactions we receive as an RDFI and the transaction unposts?

I still think you want to post that entry on the settlement date.

The only reason to back-date the forced posting to the Settlement Date would be so that it can be identified with that date in an adjustment is later required. But if a transaction attempts to post on Monday and is rejected, backdating to Monday when you force it to post on Tuesday doesn't buy your customer availability on Monday. Monday is gone, over, lost.

Unless it is an interest bearing account....

Aren't we supposed to post unposted credits by 9:00 a.m. of settlement date? I seem to recall that I used to require Operations to work unposted credits first so we wouldn't "harm" any of our customers. If we don't we could be held liable for any loss incurred by the customer. As an alternative, we can return the unposted item (of course, most of us want to be the good guy and we don't want to return credits).

In some systems you don't learn about unposted items until the end of the processing cycle on the Settlement Date.

As mentioned by rlcarey, what about the interest bearing accounts?

For example, today 4/22 Ops personnel are working on the transactions that settled as of 4/21 but didn't post.

If the decision is made to post the transactions to the customer's account, shouldn't it the effective date be 4/21?

If so, where can I find that in the NACHA rules to point it out to the supevisor of that department.

I agree that you probably have to back-date such a transaction to ensure that the interest will be correct, but don't forget to determine why the non-post occurred. If it's a bank problem, fix it. If it's a customer or ODFI problem (wrong account number or incorrect account type, etc.), send back an NOC and/or ask your customer to get it fixed.

Interest calculation and your obligation to your customer for same are contractual, and aren't covered in NACHA rules, as far as I know.

Thank you