We are going through our ACH audit and our auditor has told us that we need to have the SEC code on our statements for ACH entries. I have looked through the 2012 NACHA Rules (3.1.5.1 & 3.1.5.2) as well as Reg E (1005.9(b)) and don't see anything that would require this.

The closest thing I see is in Reg E. 1005.9(b)(iii), where it says that the "type of transfer" is required. However, in the Official Commentary, it says, "Type of transfer. There is no prescribed terminology for describing a type of transfer. Placement of the amount of the transfer in the debit or the credit column is sufficient if other information on the statement, such as a terminal location or third- party name, enables the consumer to identify the type of transfer."

To me, this means that the "type of transfer" is referring to whether it is a credit or debit, not the SEC Code. Am I missing something?

Ask the auditor where he is getting this requirement from.

Our Operations Officer has requested the information, but it may be a little bit before the auditor gets back to us. I just can't figure out where this supposed requirement is coming from.

It's not a statement requirement.

That information is going to be part of the Bank records (there are required record formats for ACH files), but it's not required on the customer statement.