It would depend on the type of ACH transaction and when it was set up. Remember that the purpose of dormant accounts as the precursor to escheatment is to determine that the customer is aware of the existence of the account. So if the ACH transactions are long-time ongoing transactions that simply occur automatically, they would not be considered "customer initiated". On the other hand, if the customer has participated this year in authorizing the ACH, that would be enough to be considered a "customer initiated" transaction. So, this could lead to an account being assessed a dormant fee for some time and not be escheated because statements are not being returned, unless the assessment of the dormant fee encourages the customer to contact the bank, and then performs a customer initiated transaction. I've spoken with the DFI about dormant accounts over the years, and they would not disagree with my analysis.