Let me guess. No one wants the responsibility, right? RDC carries the same risk factors as conventional over-the-counter paper deposits, plus the added fraud risk involved in the ability to double-dip if controls aren't in place. ACH origination if it only involves check conversions (ARC/POP/BOC) is about the same. ACH origination of other sorts presents greater credit risk in the sense that debits can come back for up to two months after the Settlement Date.
ACH is essentially an Ops function, and Ops ought to bear the responsibility for setting limits. But to the extent that the Originator is also a borrower from the bank, the folks setting the limits ought to be informed by the knowledge from the lending side of the house.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8