If you handle any of those loan acceleration programs for third parties, I need you assistance in understanding how this may apply in the following scenario which is slightly different:

Company A contracts with Bank B to originate an ACH to debit the various customers accounts on a bi-weekly basis. Funds credited to account with B. B then debits the account to make the various payments to the banks. In the missive the Company appears to be actually collecting the payments and depositing them to a fin. institution and then debits this account to make the payments. A slight difference. Opinions requested!