If we want to allow our customers to initiate ACHs via our online banking platform, what is required?

From what I am reading in the NACHA rules, it seems like we will need a written agreement between us and our customer, but that this can be done electronically. Is this right?

Does it make any difference if the customer is setting up the ACH to make a loan payment?

Are you performing a credit review of your ACH orginators?

No, do I need to? This would just be for an individual to set up a loan payment from their checking or to set up a transfer from one of their accounts here to one of their accounts at another FI. This would not be for commercial customers or third parties.