by Mary Beth Guard and John Burnett, BOL Gurus
Question: Where can I find information that can tell me any requirements for our bank if we decide to let our customers originate ACH debit/credit entries through our Internet banking product?
Answer:
Review the NACHA Operating Rules, Article Two, sections 2.1 and 2.2 and selected sections of Article Three, depending on what sorts of transactions the customer is likely to originate.
Also review Section II, Chapter I, Part B and selected parts of Chapter II, of the Operating Guidelines.
Check out Appendix Eight of the Operating Rules (Audit Requirements).
To the extent that transfers will be made that are not subject to Regulation E, review Article 4A of the UCC in your state.
The original version appeared in the September/October 2004 edition of the Oklahoma Bankers Association Compliance Informer.
First published on BankersOnline.com 3/28/05
First published on 03/28/2005
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