ICBA said it supports Nacha's plan to raise the individual same-day ACH transaction limit from $100,000 to $1 million in 2022. However, ICBA urged Nacha to assess the impact of such an increase before proceeding with its plan to remove dollar limits altogether in 2024.
While originating depository financial institutions would still retain the ability to set lower thresholds based on their risk appetite and their customers’ payment needs, ICBA said a more gradual pace will allow community banks to implement processes that address the risks associated with a higher transaction limit.
ICBA wrote that a more incremental approach would reduce risks to small financial institutions that receive large same-day ACH debits late in the day, which could unexpectedly jeopardize their liquidity.
