ACH Processing Schedules and Business Continuity Planning
Please note that all published Federal Reserve processing deadlines and funds availability schedules
for ACH processing remain in effect. Your institution should be reviewing your business continuity plan
now to ensure that you are prepared to maintain ACH payment processing capabilities in the event of
possible disruption. In addition to their own business continuity plans, financial institutions should
understand the expectations of their regulators and ACH Operators with regard to ACH processing in
potential scenarios of workforce disruption. The Nacha Operating Rules permit a financial institution to
delay performance of its obligations under the Rules beyond required time limits if:
1. The delay was caused by the interruption of communication or computer facilities; and,
2. The delay was beyond the reasonable control of the financial institution seeking the excused delay.
Whether a delay is beyond the reasonable control of the party asserting an excused delay must be
determined based on the available facts and circumstances surrounding the delay, including whether
the financial institution exercised the level of diligence required under such circumstances. A delay
caused, in whole or in part, by the failure of a financial institution to maintain or implement an
appropriate business continuity plan is not excused under the Rules for that financial institution. Please
call us at 1-800-475-0585, Option 1 if you have questions about your institution’s business continuity
plan for ACH processing.