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Dilly Labs

What's the Dilly-o with ACH, wires & real-time payments: a buyer's guide for credit unions

In the Studco case, trial testimony said a credit union's monitoring system raised "hundreds to thousands" of name-mismatch warnings a day.1 No one received a notice, and no one reviewed them.1 If your payments vendor raises alerts that nobody on your team sees, you don't have monitoring.

The Dilly-o

Our advice is to make sure your ACH and wire fraud monitoring is written down and risk-based, and that every alert reaches someone who acts on it, before you buy anything new. For instant payments, start with what your core and digital banking providers already offer, and bring in a payment hub only when they can't cover sending, wires or the volume you need.

How we'd size up a vendor

  1. Rail coverage - does the vendor cover ACH, wires, FedNow and RTP for both sending and receiving, or only some of them? Ask for the date each rail went live for a credit union your size.
  2. Fraud monitoring - does the screening cover every ACH entry type and instant payment, and who on your staff gets each alert? Ask for a sample alert report and the vendor's documented review steps.
  3. System fit - has the vendor connected to your core and your digital banking platform before, and which credit unions run that setup today?
  4. Resilience and exit - what happens to member payments when the vendor goes down, and what does it cost to leave? Get the outage plan and the deconversion fees in writing before you sign.

What changed this year

Phase 1 of Nacha's fraud monitoring rule took effect on March 20, 2026.2 Phase 2 followed on June 19, 2026, for all other business originators and third parties, regardless of volume.23 The rule requires "risk-based processes and procedures reasonably intended to identify ACH Entries initiated due to fraud."4 It reaches all ACH transaction types, where the old requirement covered only WEB debits and micro-entries.3 Monitoring before processing is optional, but you must review your processes at least once a year.2 Nacha also requires the company entry description "PAYROLL" on wage credits and "PURCHASE" on online purchase debits.3 On the instant side, FedNow raised its per-payment limit from $1 million to $10 million in November 2025.5

Will it work with your systems?

We'd check what your digital banking platform already offers before you shop. Alkami's summer 2026 release added ACH, wire and payee file mapping, and its fall 2026 release added resubmission of expired wires and ACH transactions.67 Ask your provider which rails it supports for sending versus receiving. Then ask which credit unions on your exact core and platform pairing are live today.

What other credit unions did

Veridian partnered with a service provider so it could send payments over The Clearing House's RTP network.8 AdventHealth Credit Union signed its FedNow forms on November 19, 2025 and went live on November 24.9

What your examiner will ask

NCUA's 2026 supervisory priorities name authentication, dual controls and monitoring in payment systems, along with monitoring to catch errors, fraud and unusual activity.10 For ACH, Nacha's rule calls for a documented, risk-based monitoring process that you review at least once a year.112 NCUA also warns that some credit unions signed large buyout or termination penalties thinking they couldn't negotiate, when those terms often can be.12 Bring your vendor due diligence file, the signed contract and your alert-handling procedures to the exam.

What it costs

One comparison puts both FedNow and RTP at $0.045 per payment sent and nothing to receive, with connection costs charged on top.13 DeNovo Treasury instead lists FedNow at $0.045 per payment received and typically $0.08 to $0.10 per payment sent, depending on message type.14 Since published figures differ, we'd confirm the current fee schedule with the Fed and your provider. Going through an aggregator usually adds a monthly platform fee plus about $0.10 to $0.15 per transaction, while core providers bundle RTP or sell it as an add-on.1516 DeNovo Treasury notes that pricing differs from one provider to the next.14 Plan on getting written quotes from each vendor you consider. Early termination fees can reach seven figures, and vendors may withdraw incentives and charge for deconversion and data migration.1718

Food for thought

The Fed listed 1,869 FedNow participants as of August 17, 2026, but its file doesn't show which ones can send or receive.1920

Dilly Labs research, written from our catalog and cited sources · updated . Credit unions pay nothing. Vendors pay a referral fee only when a contract is signed through us. It never changes rankings or this guide. How we work

Sources

  1. Depository Institution Not Liable in ACH Fraud Casewww.woodsrogers.com
    According to testimony at trial, this security system generated “hundreds to thousands of warnings related to mismatched names on a daily basis,” but ...
  2. Nacha Rule Changes: 1) Fraud Monitoring Phase 1 Effective Date: March 20, 2026georgiabanking.com
    Monitoring is not required pre-processing, but processes must be reviewed at least annually.
  3. Nacha Rule Changes: 1) Fraud Monitoring Phase 1 Effective Date: March 20, 2026georgiabanking.com
    The Company Entry Description field must contain “PAYROLL.”
  4. NACHA Rules Explained: What Changed in 2026oscilar.com
    - The obligation is to "establish and implement risk-based processes and procedures reasonably intended to identify ACH Entries initiated due to fraud...
  5. FedNow vs RTP 2026: Real-Time Payment Rails Comparedeco.com
    RTP settles credit transfers instantly with ISO 20022 messaging and a per-transaction limit of $10 million, raised from $1 million effective February ...
  6. Alkami’s Summer 2026 Digital Banking Platform Releasewww.alkami.com
    We have unified our high-volume file processing workflows to maximize speed and data integrity across ACH, Wires, and Payee ingestion: - **ACH, Wire,...
  7. Alkami’s Fall 2026 Digital Banking Platform Releasewww.alkami.com
    ### Resubmit expired wires and Automated Clearing House (ACH) transactions Wires and ACH transactions that expire because they remain pending without ...
  8. Tight Business Cases Accelerate Credit Unions’ Shift to Real-Time Paymentswww.pymnts.com
    The credit union’s commercial and retail clients, he said, especially wanted “send capabilities,” so the bank linked up with a service provider to tap...
  9. Credit Union Goes Live on FedNow Service in Five Dayswww.frbservices.org
    We faced zero issues or delays — we signed the forms on November 19 and went live on November 24,” notes Veronica Gurmendi, vice president of finance.
  10. NCUA’s Supervisory Priorities - A Look at What to Expect in 2026www.americascreditunions.org
    #### Payment Systems - Review/update payment system controls to ensure that appropriate authentication, dual controls, and monitoring are in place. - ...
  11. Nacha Operating Rules: 2026 Changes AP Teams Need to Knowwww.stampli.com
    Nacha’s rule does not require that fraud monitoring happen before an entry is originated. It requires that the monitoring process itself be risk-based...
  12. ​Evaluating Third Party Relationshipsncua.gov
    For example, some credit unions have entered into third party agreements with significant buyout or termination penalties, believing the penalties or ...
  13. FedNow vs RTP: US Instant Payments Comparedwww.sonicwallet.com
    In 2026 both charge the sending bank $0.045 per payment and nothing to receive.
  14. FedNow vs. RTP: What Community Banks Actually Need to Know Right Now - DeNovo Treasury Insightswww.denovotreasury.com
    Pricing varies widely by provider.
  15. FedNow vs. RTP: What Community Banks Actually Need to Know Right Now - DeNovo Treasury Insightswww.denovotreasury.com
    Typical structures include: · **Aggregator fees:** If you access RTP through a third-party aggregator, expect a monthly platform fee plus per-...
  16. FedNow vs. RTP: What Community Banks Actually Need to Know Right Now - DeNovo Treasury Insightswww.denovotreasury.com
    Typical structures include: · **Aggregator fees:** If you access RTP through a third-party aggregator, expect a monthly platform fee plus per-...
  17. Strategies for Credit Unions to Navigate Vendor Terminationswww.barclaydamon.com
    These fees – sometimes reaching seven figures – can seem like insurmountable barriers, the early termination compelling credit unions to remain tet...
  18. Strategies for Credit Unions to Navigate Vendor Terminationswww.barclaydamon.com
    Vendors might retract previously offered incentives and impose additional charges for deconversion and data migration.
  19. 1,869 Banks on FedNow, and No Way to Know Who Can Sendwww.haipay.net
    The Federal Reserve's FedNow participant list carried 1,869 institutions as of 17 August 2026.
  20. 1,869 Banks on FedNow, and No Way to Know Who Can Sendwww.haipay.net
    - The participant file records name, city and state, and no send or receive capability.
See the 26 ACH, wires & real-time payments vendorsSorted by fit with your core, with the evidence behind each.