I'd give it at least recognition. It can affect your ACH risk as an ODFI, particularly during phase 1 when debits aren't being processed as same-day items. It also has a financial impact on ODFIs, even it it's only (now) 5.2 cents per same-day item. Those nickels add up. So your policy ought to acknowledge the incremental risk and cost and address the question of pricing for Originators who generate same-day ACH entries (intentionally or otherwise).
Obviously, there are procedural tweaks that you have to make.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8