The bank received an ACH debit entry on October 11, 2019 with a settlement date of October 15, 2019. Monday was a holiday so Saturday, October 12, was a non-processing day on Tuesday's business day. The transaction was memo-posted and the funds were deducted from the customer’s “available balance” on the morning of October 12, 2019. However, it didn't hard post the account until the end of Tuesday's business day. An external auditor cited us for this by mentioning that the memo post was prior the settlement date of October 15, 2019, and it is prohibited by the rules. When I contacted Fiserv, they mentioned that there was no way around this. Is this really a violation of NACHA Settlement Date rules? If so, any advice on how to avoid this from happening in the future?
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