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ICBA sent a comment letter to Nacha’s in response to its request for comment and information regarding Same Day ACH and Faster ACH Topics. ICBA said it opposes the addition of a fourth daily Same Day ACH processing window because it would be burdensome for community banks by adding late-day operational stress, accounting challenges, and settlement risk. ICBA also opposes the acceleration of funds availability for certain non-Same Day ACH credits because it imposes undue risks and operational challenges.