We have been contacted by FIS to sign up to subscribe to this Terminated Originator database ( there is a cost of course). We are a small bank with under 100 originators and are having a time justifying the expense. Right now NACHA encourages participation, and the database is only as good as the data provided and of course is NOT a substitute for your own due diligence & underwriting... I've been asked to see what others are doing. Look forward to your thoughts.

We're in a similar position as you. However, we feel that the database isn't worth the expense. All of our originators are local and have a long-standing relationship with the community. Most also only originate payroll files. We don't allow higher-risk SEC codes (WEB, TEL, etc.). We just had an ACH audit recently and the fact that we are not using the database was never brought up.

Thank you so much for your comments..