There is significant concern that Nacha’s proposed addition of a fourth Same Day ACH (SDA) processing window will correspond with greater operational burden for many credit unions receiving depository financial institutions (RDFIs). America’s Credit Unions Director of Innovation and Technology Andrew Morris explained why  in comments sent to Nacha Friday.

“While a fourth window may offer convenience for originating depository financial institution (ODFIs) located in western regions, expansion of operating hours must be carefully weighed against the costs to other institutions who will need to maintain operations after close of business,” wrote Morris.

The fourth SDA window would align with the close of the business day in the Pacific Time Zone.

In addition, Nacha also 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.

“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,” wrote Morris.

Read the full letter.