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FED ER AL RESERVE B A * OF M E W YO R K [ Circular No. 9644 February 24, 1984 1 AUTOMATED CLEARING HOUSE SERVICES — Revised Fee Schedule, Effective March 29 — New Telephone Advice and Presorted Deposit Option Services — Plan To Reduce and Price ACH Float T o A ll D e p o s i t o r y I n s titu tio n s in th e S e c o n d F e d e r a l R e s e r v e D is t r i c t , a n d O th e r s C o n c e r n e d : The following statem ent was issued by the Board o f G overnors o f the Federal R eserve System: The Federal Reserve Board has approved a revised fee schedule for its automated clearing house (ACH) service and a plan to reduce and price ACH float over the next year. The revised ACH fee schedule becomes effective March 29, 1984. The revised fee schedule is as follows: Inter-ACH U n s o r te d P r e s o r te d I n tr a -A C H D e p o s it D e p o s it N ew Y o rk 1 Debits Originated Debits Received 1.50 0.50 3.00 1.00 2.50 1.00 2.50 0.50 Credits Originated Credits Received 0.50 1.50 1.00 3.00 0.50 3.00 0.50 2.50 Fixed AC H Fees Deposit Fees: Tape Handling File Processing $3.00 per tape $1.00 per file Receiver Handling Fees:2 Non-Electronic Electronic3 $1.75 per delivery $0.75 per transmission Telephone Advice Fees: Telephone Advices, Including Ten Pieces of Information $2.50 Each Additional Piece of Information $0.05 Night Time Deposit Surcharges Debits Originated 6.00 Credits Originated 3.00 (Next-day settlement only) 1 These fees would apply where the Federal Reserve does not operate a commercial ACH. 2 Receiver handling fees will be assessed once a day per endpoint when ACH transactions are delivered. 3 Electronic endpoints are defined as endpoints that receive ACH transactions via data transmission or receivers that pick up ACH transactions at the Federal Reserve. (OVER) In conjunction with implementing the revised fee schedule, the Reserve Banks will offer two new services — a presorted deposit option and telephone advice for night cycle transactions. Under the presorted deposit option, ACH origi nators will be assessed lower fees or be able to deposit transactions later if they sort transactions according to the receiving Federal Reserve office. Telephone advice service will be provided by Reserve Banks to depository institutions whose ACH night cycle trans actions cannot be delivered by ground transportation in time for settlement. The Reserve Banks will provide sufficient information about the transactions so that depository institutions will be able to post the transactions to their customers’ accounts on the settlement date. In addition to the revised ACH fee schedule, the Board also approved a plan to reduce and price ACH float over the next year. ACH float is generated whenever reserve or clearing accounts of the originators of ACH transactions are credited or debited before the offsetting debit or credit is posted to the receiving depository institution ’s account.4 In order to comply with the terms of the Monetary Control Act, the Reserve Banks proposed to reduce ACH float to the extent possible through operational improvements, eliminate certain types of ACH float by modifying settlement procedures, and price the re maining float. A major factor in ACH float is delayed transmissions of interregional transactions between Federal Reserve offices. By implementing operating improvements, the Reserve Banks expect to reduce this float to approximately $7.0 million by the fourth quarter of 1984. The annualized value of this float is included in the cost base of the 1984 fee schedule. Float resulting from the inability to process ACH paper return items within the current availability schedules is an other source of ACH float. ACH paper return item float will be reduced by changing the current availability schedule for interregional ACH paper return items from same-day to next-day settlement. Any residual float will be included in the ACH cost base the next time ACH fees are set. Midweek closing and nonstandard holiday ACH float results from an inability to post ACH transactions to the ac counts of depository institutions that are closed during the middle of the week (midweek closings) or on nonstandard holi days when the Reserve Bank is open. With regard to midweek and nonstandard holiday ACH float, the Board determined to follow the same procedures that were recently adopted for midweek and nonstandard holiday check float. 4 Originators of debit transactions are receivers of funds and their accounts are credited on the settlement date. If the receiving depository institution’s reserve or clearing account is not debited on the settlement date, debit float is generated. Originators of credit transactions are payors of funds and their accounts are debited on the settlement date. If the receiving depository institution’s reserve or clearing account is not credited on the settlement date, credit float is generated. The B oard’s official notice in this m atter will be published in the Federal Register, and copies will be m ailed to depository institutions in due course. Copies will also be furnished upon request directed to our Circulars D ivision (Tel. No. 212-791-5216). Questions on this m atter should be directed to Andrew H eikaus, M anager, Funds Transfer D epartm ent (Tel. No. 212-791-5565). A nthony M . S olom on, President. FEDERAL RESERVE SYSTEM Docket No. R-0482 FEE SCHEDULES FOR FEDERAL RESERVE BANK SERVICES AGENCY: ACTION: Board of Governors of the Federal Reserve System. Fee Schedule and Float Reduction Plan for the Automated Clearing House Service. SUMMARY: The Board of Governors of the Federal Reserve System (nBoard°)f pursuant to the requirements of the Monetary Control Act of 1980 (°MCA°) (12 U.S.C. § 248a)* has adopted a revised fee schedule for its automated clearing house (°ACH°) services and a plan to reduce and price ACH float over the next year. The revised fee schedule is as follows: Basic ACH Transaction Fees Intra°ACH __________ Inter°ACH______________ Unsorted Presorted Deposit Deposit New York.!/ Debits Originated Debits Received 1.5* 0.5* 3.0* 1.0* 2.5i*f l.OC 2.5* 0.5* Credits Originated Credits Received 0.5* 1.5* 1.0* 3.0* 0.5* 3.0* 0.5* 2.5* Fixed ACH Fees Deposit Fees: Tape Handling File Processing $3.00 per tape $1.00 per file 1/ These fees would apply where the Federal Reserve does not operate a commercial ACH. [Ref. Cir. No. 9644] r -2- V__ Receiver Handling Fees:.?./ Non=Electronic Electronic.?/ Telephone Advice Fees: $1.,75 per delivery $0«75 per transmission Telephone Advices, Including Ten Pieces of Information $2o50 Each Additional Piece of Information $0o05 Night Time Deposit Surcharges Debits Originated 6„0^ Credits Originated 3 o0^ (Next=day settlement only) EFFECTIVE DATE: March 29, 1984* FOR FURTHER INFORMATION CONTACT: Director (202/452=2231) (202/452=3955), Elaine Division, Mo or Florence M 0 Young, Division of Federal Gilbert To Schwartz, or Elliott Co McEntee, Associate Reserve Associate General "Boutilier, Attorney Board of Governors Program Manager Bank Counsel Operations; (202/452=3625) (202/452=2418), Legal of the Federal Reserve System, Washington, Do Co 20551o SUPPLEMENTARY INFORMATION : The MCA requires that fee schedules be developed for Federal Reserve Bank services based on pricing principles established by the Board0 In 1982, the Board determined to phase out its incentive pricing policy for ACH services0 the ACH fee schedule, Accordingly, established on December 30, 1982, provided for recovery of 40 percent of the 2/ Receiver handling fees will be assessed jsnce a day per endpoint when ACH transactions are deliveredo 3/ Electronic endpoints are defined as endpoints that receive ACH transactions via data transmission or receivers that pick up ACH transactions at the Federal Reservec -3- costs of providing commercial ACH services. Consistent with the phase-out of incentive pricing for commercial ACH services, in September ,1983, the Board restructured fee schedule commercial ACH costs. requested which would 48 F.R. 44650 public recover comment on a 60 percent of (September 29, 1983). In addition, the Board requested comment on plans for eliminating and/or pricing ACH float, and potential near-term and long-term service enhancements. A total of 123 comments were received from the public. Background The ACH fee schedule that was implemented on December 30, 1982, was based on an incentive pricing policy, as noted alcove. only per The schedule item fees, and funds-=institutions is a national assesses sending schedule, fees only debits to includes to receivers collect payments of and institutions receiving credits, such as salary payments. The proposed fee schedule differed fee schedule in several significant from the respects. current First, the majority of fees were set at the district rather than national level. to Second, per item fees were supplemented with fixed fees recover preparing advising the institutions with handling deposits, of the receipt of ACH them, payments and by Third, two surcharges were proposed that would be to surcharge, associated transactions for delivery and delivering telephone. assessed costs all was originators. intended to One, recover a low volume a portion of receiver the costs -4- incurred in providing institutions. The services other, intended to recover an to a large number interregional of surcharge, from was the costs of processing ACH transactions that, must be handled by two Federal Reserve offices. case, small In each the surcharge was based on the benefits to originators being able to send transactions institutions throughout the country. to assess privately operated ACHs to many Finally, the same depository it was proposed fees charged to other users, when they use "the same services. Proposed ACH Fee Structure Public commenters discussed a number concerning the proposed ACH fee structure. into three broad categories: underlying the fee structure; and (3) (1) of issues Their concerns fell the .pricing principles (2) the specific fees proposed; the approach for pricing the ACH services used by privately operated ACHs. Less than half of the commenters discussed the use of incentive pricing for the ACH service. All but two of these respondents supported the planned phase-out of the policy and indicated that an immediate move to full-cost pricing for the Federal Reserve's commercial ACH services would negatively affect ACH volume growth. Therefore, the Board has determined to continue of Accordingly, its phase-out incentive pricing the new fee schedule will recover the costs of commercial ACH services for 1984. as planned. 60 percent of -5- The concept of value pricing has been some extent, August, since ACH 1981. fees A majority concept of value pricing were of to implemented in that discussed the originally respondents indicated employed, that the Federal Reserve should base its fees solely on the costs it incurs in providing services. A slight majority of commenters that discussed the concept of benefit-flow pricing that it was inappropriate for the judgments about perceived benefits. Federal specifically also Reserve indicated to make Several commenters stated that the use of value pricing was inconsistent with the intent of the MCA and would inhibit private sector competition. After policy, taking into account the ACH the proposed ACH incentive pricing fees w-ere set so that they would recover the total costs, plus the PSAF, of providing commercial ACH services. Therefore, the proposed ACH fee schedule is consistent with the MCA, which specifies that: Over the long run, fees shall be established on the basis of all direct or indirect costs...including interest on items credited prior to actual collection, overhead, and an allocation of imputed costs which takes into account the taxes that would have been paid and the return on capital that would have been provided had the services been furnished by a private business firm, o . o J/ The use of value pricing has a sound basis in economic theory. services. y Scale economies in the provision of ACH The use of value pricing assists in the realization 12 U.S.C. § 248a(c)(3) exist -6- of the scale economies and saves real resources, stimulates demand by establishing prices that users8 demand elasticities, that is, the because it reflect various relative benefits user^s realize,, An update of the analysis performed in 1982 indicated that receivers of funds still derive greater benefits from the ACH than payors of funds,, Although all participants appear *to be able to realize some operating cost savings through the ACH, receivers' of funds credit for payments checko Conversely, have than the additional they would benefit receive of earlier in payments by payors of funds are charged for payments earlier than they would be if they made payments by check„ The opportunity costs associated with the value of float that is lost when the ACH is used has been one of the principal deterrents to ACH volume growth. One of the involvement in the development of an reasons ACH for was to electronic the Federal provide payments Reserve’s support service for the that would improve the efficiency of the nation's payments mechanism. The Federal Reserve has played an active role in promoting the ACH since its inception during Reserve's pricing policies efforts to promote Federal Reserve the 1970s. The are consistent with the A C H „ commercial early Further, ACH fees to the are set its Federal historic extent at levels that that stimulate demand for ACH services, the Federal Reserve’s use of value pricing should assist depository institutions in their -7- efforts to increase ACH usage among their customers since the fees reflect the relative demand for ACH services. Similarly? the use of value pricing Reserve should not inhibit private-sector private sector has as much or prices as the Federal Reserve? more and? by the Federal competition. flexibility in The setting in fact, value pricing is often used by depository institutions in pricing their payment services. The Federal Reserve has adopted pricing principles that require the Reserve Banks to match costs and revenues for each separately priced service. This requirement is more stringent than the requirement in the MCA, which only indicates that all Reserve Bank services must be explicitly priced and that fees must* be based on all direct Further? users of payments services, and indirect costs. including ACH services, consider a number of criteria? such as service levels? quality, and price? in determining services. Therefore, price is not the only basis upon which service suppliers frequently willing the supplier compete. to pay Users higher of from which payments fees for to obtain services higher are levels of service or to pay a premium for a high quality of service. Accordingly? the Federal Reserve's use of value pricing satisfies the requirements of the MCA, provided that the fees established are intended to recover indirect costs plus the PSAF? Federal Reserve's scale economies after taking all direct and into account the incentive pricing policy. exist in ACH operations, the Further? use of because value -8- pricing should stimulate demand for ACH services and, provide for a more efficient use of real resources. thereby, Therefore, the Board determined that the ACH fee schedule should continue to incorporate value pricing concepts. Nearly proposal to 60 percent assess fees of the that commenters varied by discussed Federal the Reserve District. Approximately one-half of the commenters favored the proposal, while the other half preferred national fees. Opponents of regional fees indicated that they would encourage geographic volume shifts that might create a competitive imbalance among depository institutions and exacerbate the unit cost differentials between high and low volume Federal Reserve processing facilities. During transactions Therefore, 1983, approximately originated were 60 percent interregional based on the composition of ACH of all ACH payments. transactions, it appears that the ACH service is primarily national in character. Because the ACH is still an emerging payments mechanism, as ACH volume levels increase and the transition to a primarily processing electronic cost mechanism differences Should be reduced. among is accomplished, Federal Reserve unit offices To the extent that higher ACH fees in lower volume Federal Reserve Districts could act as a deterrent to volume growth, such a move would be inconsistent, at this time, with the Federal Reserve's broader goal of promoting the ACH. -9- The Board decided that it is premature regional ACH fees. to implement Because the ACH is not a mature payments service and has not yet reached its potential as a primarily electronic mechanism, the use of regional fees may not reflect the long-run cost structure of the ACH« service matures, the regional rather than Federal a Reserve national fee However, may as the ACH determine structure that is a more appropr iate. Proposed overall Schedule--Commenter s impact of the proposed individual proposed inhibit Fee fees. fee A number schedule, future volume fee schedule of commenters with its growth. discussed as well suggested the as the that various surcharges, Several commenters the would also indicated that the overall impact of the proposed fees resulted in a departure from benefit-flow pricing. A comparison of the overall impact of the proposed fee schedule with the existing fees indicated that the proposed fee schedule departed from the concept of pure benefit-flow pricing in two ways. fees, not First, just transactions and all ACH participants would be assessed receivers receivers of funds of credit (originators of transact ions) . debit Second, the fees that would be assessed to the various participants did not reflect the relative benefits realized by eacho Under the proposal, fees assessed to receivers of credits were lower than the present fees, even though they achieve the greatest benefit -10- from the ACH. credit On the other hand, the charges to originators of transactions increased the most although these participants realize a lesser benefit from the ACH due to the loss of float,. transactions, From the standpoint of originators of credit the level of the proposed charges could have negatively affected volume growtho The Board has determined that the use of value pricing (and thus benefit-flow pricing) assists in stimulating ACH volume growth, yet at the same time, the use of these concepts does not preclude participant, schedule provided reflects participanto assessing the that some the relative Therefore, charges overall benefits to impact each of realized ACH the by fee each the ACH fee schedule was modified to retain the concept of benefit-flow pricing but also to assess fees to all participants„ Fixed Deposit Fees— The fixed deposit fees included in the proposed fee schedule were to be assessed for each file— ^ an ACH originator deposited with the Federal Reserve0 Approximately 60 percent of the commenters that discussed fixed deposit fees supported the concept. Respondents that opposed the fees indicated that they discriminated against low volume originators. !/ A file is defined as a group of transactions addressed to a specific Federal Reserve office. All unsorted deposits are addressed to the local Federal Reserve office? presorted deposits would include files addressed to sever al Federal Reserve offiees0 -1 1 - The containing costs ACH involved deposits included on the tapes as or in handling well files as the magnetic processing transmitted the to the tapes files Federal Reserve are essentially the same regardless of the number of transactions included in the deposit,, costs are fixed* effectively Further* operating through experience the in use the costs of Since deposit handling cannot be transaction check recovered fees collection alone,, service indicated that fixed fees provide an incentive for has users of payments services to use them efficiently,, Some commenters pointed out that fixed deposit fees would affect originators of ACH transactions differently,, It is true that the per transaction impact of the proposed fixed deposit fee would be greater for high volume for low volume originators than originators. However* the per transaction impact of any fixed fee declines sharply as volume increases. Finally* some commenters indicated that tape handling was more costly than file processing because tape handling is a labor-intensive activity and file processing function. A detailed analysis of the is an automated costs incurred in processing incoming ACH deposits indicated that the fixed costs of handling tapes are approximately three times greater than those for file processing. Because the costs incurred in handling magnetic tapes and processing files do not vary in relation to the number of transactions deposited* the Board approved a fixed deposit -12fee. However? as the costs of handling magnetic tapes are considerably higher than the costs of processing files? the proposed deposit fee? which was originally based solely on the number of files deposited? was modified to include a tape handling fee and a file fee. These fees will apply on a per processing cycle basis for each magnetic tape and each file an originator deposits? unless an originator deposits more than one magnetic tape or file at the request of the Federal Reserve. In this case? the fee may be waived. For ACH originators that deliver deposits via data transmission only the file fee would apply. Fixed Receiver Handling Fees— The proposed fixed receiver handling fees were to be assessed on the basis of delivery points? or endpoints? and reflected the higher costs of serving non-eleetronie versus electronic receivers. About half of the respondents that discussed the receiver handling fee'supported the concept. However? a number of commenters indicated that the fees could potentially have a negative impact on low volume ACH participants. As in the case of the fixed deposit fee? the fixed receiver handling fee was intended to recover the fixed costs associated with generating ACH output? preparing it for delivery? and effecting delivery over the road or via data communications. Since these costs are comparable over wide volume ranges? the fixed receiver handling fee parallels the Reserve Bank's cost structure. -13- Currently, participate delivered in to about institutions have correspondent volume and the about 20,000 ACH. However, 10,000 their banks 10,000 or depository ACH endpoints, ACH transactions since transactions service bureaus. endpoints, the many are smaller intercepted Based average received over 60 transactions per day. institutions ACH on by 1983 ACH participant Thus, the impact of the proposed receiver handling fee would have ranged from less than lo0 cent per transaction to about 3.0 cents per transaction. Although the effect of a receiver handling fee would be greater for very low volume institutions, these institutions from being about to provide the ACH services their benefit customers demand and also from achieving operating cost 'savings through use of the ACH. receiver As a result, the impact of the proposed handling fee should not be a significant factor in smaller institutions0 decision to participate in the ACH. handling recover The Board fee is necessary endpoint, correspondent as to enable whose banks proposed, ACH or the receiver were set at a lower non-electronic that ACH a fixed receiver the Federal Reserve services to low to volume By assessing the fee on a delivery point, basis, institutions determined the costs of providing institutionso Finally, has its impact transactions service are bureaus on smaller processed will or be by reduced. handling fees in the original proposal rate receivers. for electronic receivers Because of the than for efficiency of -1 4 - electronic delivery mechanisms, in the final fee schedule. institutions located this differential is included In addition, a number of depository in Federal Reserve cities pick up their ACH transactions at the local Federal Reserve office. these arrangements reduce transportation costs, Because the electronic handling fee rather than the non-electronic handling fee will be assessed to these institutions. Telephone Advice Fees°°In conjunction with permitting all types of ACH transactions to be deposited at the night time deposit deadline, the Reserve Banks also expanded their telephone advice services for depository institutions that do not receive these night cycle transactions on the settlement date. fixed Because the amount of information requested may vary, a fee variable proposed. for fee the for first each ten pieces additional of piece information of and information a was A majority of respondents supported these proposed fees. The provision labor“intensive of activity telephone and fixed advice costs services are is incurred accumulating data and in placing telephone calls. a in However, the amount of data provided to each receiving institution may vary due to differences in transaction volumes or the needs of the receiving institution. As a result, there is some variability in the costs of this service. Therefore, the Board determined that the telephone advice fee should be included schedule as proposed. in the fee -15- Basic Transaction Fees— Under the proposal, the basic transaction fees were intended to recover the costs of editing and sorting transactions and were to be assessed to originators of debit transactions and receivers of credit transactions. Several commenters suggested that all ACH participants realize benefits from the ACH and suggested that transaction fees be assessed to both parties to a transaction, like they are for the wire transfer of funds service. Because substitute for the paper ACH was checks, originally fees for established on a comparable basis, conceived ACH that as services is, a were they have been assessed to receivers of funds and to only one party. However the ACH is an electronic payments service that offers its users many benefits they payments services, and security. participants could not such as, Thus, derive as obtain through paper-based increased certainty, commenters benefit from pointed the ACH. convenience, out, all Therefore, transaction fees will be assessed to all ACH participants, but the benefit-flow concept will be retained to reflect the relative benefits of each participant. Low Volume Receiver Surcharge°°The proposed low volume receiver surcharge was to be assessed to ACH originators for each transaction sent to an ACH participant that received fewer than 500 transactions per day. This element of the proposed fee structure was opposed by 101 commenters and was supported by only four respondents. Commenters indicated that the -16- surcharge would inhibit volume growth because it would have a significant Further, impact on commenters originators indicated of that credit transactions. originators of ACH transactions do not influence the destination of transactions. Rather, consumers receiving and receiving depository indicated that operationally the companies institutions. low volume Finally, receiver complex proposal select their commenters surcharge was an both from the perspective of depository institutions and the Federal Reserve. While it is true that neither depository institutions originating ACH transactions nor their corporate customers determine the institution that will receive an ACH transaction, originators do institutions. development, benefit However, from a given broad the base current of receiving state of ACH it appears the costs and potential complexity of implementing the low volume receiver surcharge could negatively impact future volume growth. Therefore, until additional analysis is done, the low volume receiver surcharge will not be implemented. Interregional Surcharge— The current ACH fee schedule includes an interregional benefit°flow basis differential to originators receivers of credit transactions. published for interregional both debit public comment differential, and credit or that of debit is assessed on a transactions and The fee schedule that was proposed surcharge, transactions. assessing the to originators In addition, a of lower -1 7 - surcharge was proposed for transactions included deposits than for transactions in unsorted or mixed included in presorted deposits. A majority of commenters supported the proposal. However, a few commenters indicated that the surcharge should continue to be assessed on a benefit-flow basis. Other commenters suggested that the surcharge should be split between originators and receivers of ACH transactions. Assessing originators, the interregional surcharge to all ACH in conjunction with assessing them fixed deposit fees and the low volume receiver surcharge, was determined to be inconsistent Therefore, the closely the This was with fee the concept schedule was relative benefits done in part, by of benefit-flow modified to realized by assessing reflect ACH the pricing. more participants. interregional differential to all ACH participants in the same way as basic transaction fees. Further, because less processing is required when presorted deposits are received, a lower fee will be assessed to originators depositing presorted transactions. Night Time Deposit Surcharges--The proposed fee schedule, like the current fees, included surcharges that would be assessed to originators of both debit and credit transactions deposited at the night time deposit deadlines. Commenters the night time deposit surcharges indicated that should reflect only the specific costs associated with night time operations and that these costs would same for both debit and credit transactions. logically be the -1 8 - As indicated in the discussion of value pricing, appropriate for the Federal Reserve to adjust individual components of priced services so that the relative benefits realized by users0 fees it is for they reflect Originators of debit transactions realize substantial benefits from the use of night time operations through improved funds availability. Conversely, the only benefit derived by originators of next-day credit transactions from the night additional processing time. generated as a deadline is Furthermore, there is also a cost basis for assessing different float time deposit fees, result of because delayed the majority of interregional transmissions is due to debit transactions processed at night. Because originators of debit and credit transactions realize different benefits and because there are processing costs differences, a higher night time deposit surcharge will continue be assessed to originators of debit transactions than to originators of next-day settlement credit transactions. No night time deposit surcharge will be assessed to originators of two-day settlement credits. Corporate Trade Payment Fees°°Because very low volumes of corporate through the indicated trade ACH, payments the (°CTP°) proposal that the CTP fee were issued schedule for being processed public implemented comment on June 2, 1983, would remain in effect until more experience was gained with the application. aspect of the proposal, Very few commenters discussed but those that did generally this agreed -19- that the current fee schedule should not be modified at this time. Accordingly, effect, with handling, the and applications, the current exceptions telephone fee schedule will that advice fixed fees will remain deposit, apply in receiver to all ACH including the CTP application. Proposed Fees for Privately Operated currently assessed to the New York Automated ACHs°°Fees Clearing House Association (0NYACHf’) are based on the same concepts underlying the present national fees, however, participants, structure. The basic transaction are lower than the fees assessed to other ACH because the New York Federal Reserve Bank does less processing ACH. fee than Reserve Banks that operate a commercial The following changes in this philosophy were proposed: (1) when privately operated ACHs use the same services that are used by depository institutions, the same fee should be assessed and (2) when unique services are provided to privately operated ACHs, they should be priced separately to reflect the actual costs incurred in providing the services. In its response, the New York Clearing House (QNYCH") indicated that the nature and level of the proposed fees would discourage competition with the Federal Reserve and might affect the Clearing House's ability to continue to operate an ACH. Specifically, the NYCH indicated that the fee structure required■NYACH to pay for services that it does not use, such as, commercial ACH processing, ACH return item processing, customer support services. and Thus, the NYCH concluded that ACH -2 0 - fees for privately unbundled. operated ACHs had not been sufficiently Howeverf in discussing the proposal to unbundle the settlement services questioned the provided fee because to it the Clearing °is not assessed Federal Reserve operated ACH.° that the proposed? NYACH? Finally? unbundled deposit? the House against NYCH settlement? any indicated and delivery fees were higher than comparable fees in other Federal Reserve Districts o The question of whether the proposed fee schedule required NYACH to pay for services that it does not use can be addressed by schedule.. in the individual elements of the fee First? NYACH deposits interregional ACH transactions files office., reviewing that are presorted by receiving The Reserve Banks plan to make Federal this Reserve deposit option available to all ACH originators when the new ACH fee schedule is implemented. Accordingly? it was proposed that NYACH be assessed the same transaction fees and interregional surcharges as any presorted depositor. In this case? it is clear that NYACH receives the same service as other ACH originators? and this element of the proposal treats NYACH equitably. Second? originated proposed above? the and credits in other basic transaction received Federal were Reserve fees the same Districts. this is appropriate for presorted debit However? in the case of credits received? for debits as the fees As indicated transactions. the proposed fee schedule did not reflect the fact that the New York Bank does = 21- less processing. operate a In regions where the Federal Reserve does not commercial AC H * privately operated ACHs for transaction fees assessed to receiving ACH transactions should be lower than the fees assessed to ACH participants where the Federal Reserve operates an ACH. Third* a settlement charge consisting of a fee per settlement statement as well as a fee per settlement entry was proposed. This fee was intended to recover costs incurred in processing settlements for NYACH. Since commercial ACH transactions are processed by all other Reserve offices* the settlement of transactions is not a separate activity but an integrated processing step. As such* the costs associated with settlement are recovered through basic transaction fees. The Federal Reserve has defined its net settlement services as the posting of net debit or net credit entries to the reserve or clearing accounts of institutions participating in clearing arrangements where the Federal Reserve process any of the underlying transactions. does not In the case of net settlements processed for the NYACH, the net entries represent both local ACH transactions* which the Federal Reserve is not involved in processing* and interregional ACH transactions, which the Federal Reserve is involved in processing. Because of the unique nature of the settlement services provided NYACH* it is considered to be appropriate to continue to to recover the costs the New York Bank incurs through transaction fees* for the present. The handling of settlements that -2 2 = combine transactions that the Federal Reserve has not processed with those it has been involved in processing is a complex issue,, In addition* it is an increasingly important issue because procedures currently in place result in float generated by privately operated ACHs being reflected on the Federal Reserve’s balance sheeto Therefore* a comprehensive analysis is being conducted of the issues concerning accounting and settling for ACH transactions in regions where the Federal Reserve does not operate a commercial ACH0 (It should be noted that if a privately operated ACH requested net settlement services for ACH transactions that the Federal Reserve is not involved in processing* it would be assessed the Federalj Reserve’s net settlement fees„) Fourth* it was proposed to assess fixed deposit fees and a combined settlement and ground delivery fee to privately operated ACHs0 The fixed deposit fee and the ground delivery fee were set on the same basis as the fees for all ACH participants institutions identical,, feeso because and the services private°seetor provided ACHs to are depository essentially The NYCH’s primary concern was the level of the Because the Board determined that the ACH continue to be considered a national service* should the concerns raised by many commenters* including NYCH* regarding the.range of the proposed fixed fees have been addressed by the adoption of uniform fixed fees0 “ 23- ACH Software--The proposal issued for public comment also indicated that ACH associations wishing to use the Federal Reserve's new ACH software package, ACH-84, would be assessed a licensing fee as well as an annual maintenance fee. The ACH-84 software Federal package is currently being developed by Reserve staff and should be completed during the fourth quarter of 1984 . Commenters Automated Clearing indicated House their ("NACHA®) belief that as well as the National the Federal Reserve had proprietary rights to the ACH-84 software, the current ACH software Reserve and NACHA. is jointly owned by the since Federal In addition, because costs associated with software development are included in the cost base used in setting commercial ACH fees, respondents believed that it was inappropriate for the Federal fee* Finally, a few commenters Reserve's legal authority broad range of conducted before issues Reserve to sell raised, the Board to assess questioned software. additional determines a licensing the Federal Because analysis whether to of the will be adopt the licensing and maintenance fees. ACH Float ACH float is generated whenever reserve or clearing accounts of the originators of ACH transactions are credited or debited before the offsetting debit or credit is posted to the -24receiving depository institution's comply with the terms of the MCA, to; (1) reduce operational ACH float improvements; float by modifying to the account.-^ In order to the Reserve Banks proposed extent possible (2) eliminate certain settlement procedures; and through types of ACH (3) price the remaining float. Delayed Interregional Transmission Float°°The primary cause of ACH float is delayed transactions delayed between Federal transmission float transmissions of interregional Reserve amounted offices. to During 1983, approximately $36 million on a daily average basis and accounted for 53 percent of total ACH float. The Reserve Banks azle in the process of implementing operating improvements that are expected to reduce this float to approximately $7.0 million by the fourth quarter of 1984. of It was proposed to incorporate the annualized value projected, fourth quarter, 1984 delayed interregional transmission float in the cost base used to derive the revised ACH fees. A majority of respondents indicated that it is inappropriate for the Federal Reserve to charge for its §./ Originators of debit transactions are receivers of funds and their accounts are credited on settlement date. If the receiving depository institution's reserve or clearing account is not debited on the settlement date, debit float is generated. Originators of credit transactions are payors of funds and their accounts are debited on settlement date. If the receiving depository institution's reserve or clearing account is not credited on the settlement date, credit float is generated„ . . -25- operational inefficiencies and that such a step would remove the incentives for further improving operations. Inclusion of this base is consistent Reserve float with remaining improvements. float the MCA, after Furthermore, i.n the commercial since it prices implementation this action will of ACH cost Federal operational increase the Reserve Banks0 incentives for improving operational procedures because including the value of this results in higher ACH fees. projected, fourth float in the cost base Therefore, the annualized value of quarter, 1984, delayed interregional transmissions float will be included in the 1984 commercial ACH 7 / cost base.— ! 1 Return Item Float— Float resulting from the inability to process availability float. ACH paper schedules During 1983, return items is the second within largest the current source of ACH return item float amounted to nearly $18 million on a daily average basis and accounted for 26 percent of total ACH float. The request for public comment proposed to eliminate the majority of this float by changing the current availability schedule for interregional ACH paper return items from same-day to next-day settlement. The majority of respondents supported this proposal, and it has been adopted by the Board. V In conjunction with this action, to encourage Us ing a 9.5 percent .Federal funds rate,, the value of this float amounts to $655,000. = 26 = greater use of the automated ACH return item process, the Reserve Banks plan to change the current availability schedule for automated return deadline from items next-day deposited to same-day at the morning settlemento deposit It is anticipated that the majority of return item float should be eliminated by these modifications. Any residual float will be included in the ACH cost base the next time ACH fees are set, Midweek Closings and Non-standard Holiday Float-°Float resulting from the inability to post ACH transactions to the accounts of depository institutions that are closed during the middle of holidays the week amounted basis in 1983 0 (midweek closings) or on non-standard to abcfut $4.0 million on a daily average As a means of eliminating this float, it was proposed to debit or credit the reserve or clearing account of the closed institution as though the institution were open for business. A majority of commenters supported the proposal, although some respondents stated that accounts should not be charged when state law requires depository institutions to be closed o Although a majority of the respondents supported the proposal to charge the accounts of institutions closed during the middle of the week as though they were open, determined that it is appropriate to offer the same options as these collection service. recently these adopted for the Board institutions the 49 F.R, 4196 (January 30, 1984). check -27- Wit h respect to ACK debit transactions, depository institutions that elect to close during the business week will be offered the following options; (1) having the Reserve Bank debit its accpunt for items that are made available to it and would normally be settled on that day if the institution were open for business; or (2) paying for the value of float that is generated., may pay Under for the second float procedures: (1) option, explicitly payment depository through may be one made of institutions the through following an °as ofra adjustment to an institution's reserve or clearing account to correct for float after it has occurred; or (2) payment may be made by an explicit transactions, charge., depository In the case institutions' of ACH accounts credit will be credited for transactions that settle on midweek closing days. With respect to float observing non-standard holidays, feasible, Reserve originators of Banks ACH will arising from institutions' to the extent defer transactions debiting that are operationally or crediting destined for institutions that will be observing a non-standard holiday on the settlement date., The value of any remaining non-standard holiday float will be recovered under the fee schedule., Residual ACH Float°°The approximately 15 percent, due to Reserve Bank remainder of ACH float, amounting to about $11 million, operating procedures, processing is or intraterritory transportation delays, and reserve adjustments. Because this float can be reduced substantially through = 28 = operational improvements, it was proposed that operational improvements be implemented during 1984 and that any residual float that cannot be eliminated be included base the next time ACH fees are set. that delaying the pricing of in the ACH cost One respondent suggested residual ACH float created a competitive advantage for the Federal Reserve0 Because much of this float results from operational inefficiencies inherent in the current ACH software that will be corrected when the ACH=84 software is implemented later this year, this float will not be until joperational included improvements can be in the ACH cost base realized. Since the majority of ACH float will either be included in the 1984 ACH cost base or be eliminated, this procedure does not create a competitive advantage for the Federal Reserve. Proposed Service Enhancements Based on a review of the current features of the ACH service, several service enhancements were identified. proposed to; It was (1) offer several alternative levels of telephone advice services to depository institutions for items deposited at the night time deposit deadline that cannot be delivered on the settlement date? (2) offer depository institutions lower prices and/or later deadlines for deposits that are presorted by receiving Federal Reserve District and are delivered either to the local Federal Reserve office or the Federal Reserve office serving the receiving i n s t i t u t i o n s ) ? and. (3) conduct an analysis of offering same=day settlement for ACH transactions, -29- expanding the ACH value-dating concept or providing a warehousing service, modifying the ACH to serve as a mechanism to facilitate interbank clearing and settlement of electronic payments, converting ACH paper return items to automated form at the Federal Reserve office of first receipt, and offering a separate ACH return item service. With respect to the proposed service enhancements, commenters issues. offered many At this time, suggestions and raised the numerous only the telephone advice service and the presorted deposit option can be implemented in conjunction with the revised ACH fee schedule. Before considering whether the other proposed service enhancements should be offered, a complete analysis of their potential impact on the ACH service will be conducted. Telephone Advice Service--In conjunction implementing the revised ACH fee schedule, with it was proposed that the following alternative telephone advice services be offered to depository totals? debit advice institutions: (1) advice of ACH (2) advice of all debit transactions; transactions of all above credit a specified transactions; transactions above a specified dollar dollar (5) (3) advice of 8 amount;— advice amount; settlement of / (4) credit (6) advice of next-day settlement credit transactions only; or (7) a J/ A specific dollar amount will be determine jointly by representatives, of the Federal Reserve and each depository institution. = 30 = combination of institution0 these alternatives In providing selected these services, by a depository the Reserve Banks would provide sufficient information about transactions so that depository institutions would be able to post the transactions to their customers" accountSo This proposal was supported by the majority of respondents that discussed it. Because ACH transactions processed at night cannot'be delivered to remotely located institutions transportation by the settlement date, advice services will be made via ground the proposed telephone available to depository institutions by all Reserve Banks where there is a demand for such services beginning March 29, 1984. Presorted Deposit Option— Currently, Federal offices accept only mixed, or unsorted, ACH deposits0 number of depository institutions possess sort ACH transactions and are believed Reserve Since a the capability to be interested to in reducing the costs associated with participating in the ACH, a presorted deposit option was proposed. Under this option, ACH originators would be permitted to deposit transactions sorted by receiving Federal Reserve office with their office or to deliver presorted deposits local Reserve directly to the receiving Reserve office. A majority of commenters supported R e s e r v e d offering a presorted deposit option, the Federal indicating that this proposal was a positive step for improving the efficiency of the ACH mechanism. Several commenters, however, noted that = 31 = deposit deadlines were not identical at all Federal Reserve of f ices. Since the presorted deposit option offers originators of ACH transactions a meaningful way to reduce costs or to benefit from later deposit deadlines and should contribute to ACH volume growth, the Reserve Banks will begin offering the presorted deposit option on March 29, 1984. In addition, each Federal Reserve office will make a schedule of all ACH deposit deadlines available to originating institutions that desire the schedules. Cost, Volume, and Revenue Projections Based on preliminary data, recoverable commercial ACH costs, during 1983, total including the PSAF, amounted to $6.2 Total revenues amounted to $6.6 million, resulting in a net revenue surplus of $400 thousand. These results compare favorably with the projections that were used in setting the current ACH fees. that recoverable Specifically, commercial the Reserve ACH costs would Banks projected amount to $5.7 million and that total revenues would amount to $6.0 million. The primary reason for the differences in both commercial ACH costs and exceeded revenue was projections. commercial ACH transactions. approximately volume The 156 fact million that Reserve would Preliminary processed during 1983. the commercial Banks amount volume commercial to data ACH ACH volume estimated 151 that million indicate that transactions were -32 = The Reserve Banks project that recoverable commercial ACH costs, including the PSAF and the float that will be included in the cost base, will amount to $10.6 million during 1984 . Based on the recommended ACH fee schedule, expected to amount to S l i d revenues are million, resulting in a net revenue surplus of $500 thousand. The increase in costs reflects the change from a 40 percent to a 60 percent recovery rate, the inclusion of ACH float in the cost base for the first time, as well as a slight increase in the proportion of commercial ACH volume to total ACH volume. During 1983, commercial ACH transactions constituted approximately 39 percent of total ACH volume. 1984, commercial ACH volume In is expected to reach a level of 187.8 million transactions to account for nearly 42 percent of the estimated 452.4 million government and commercial ACH transactions. By order of the Board of Governors of the Federal Reserve System, February 15, 1984. (s ig n e d ) W illia m W. W i l e s William W. Wiles Secretary of the Board