If the ACH item is an RCK, ARC, POP, or BOC, I believe that it fits the phrase "check, draft, debit card,
or similar order made by the depositor and payable to third parties" and should be counted as if it were a paper check payable to a third party.
What I truly believe is that the Fed should find a way to finalize its proposal of last year to eliminate the special limit for checks, drafts, debit cards, etc.
Not that they have anything else more important to be concerned with
.