who am I - internet banking

Posted By: maggie mae

who am I - internet banking - 08/29/08 01:44 PM

We are soon to offer our Internet banking customers the ability to make interbank transfers. It would appear that we would then be both the Originator and the ODFI. The only ACH information I can find relating to online consumer transactions are those applicable to WEB transactions (purchases). Where do we fall in the ACH picture? Is the inclusion of a standard Originator / Client agreement in our online disclosure sufficient?