Whoever "they" are needs to review the NACHA requirements.
SUBSECTION 2.2.2 ODFI Agreement with Originator, Third Party Sender or Sending Point
SUBSECTION 220.127.116.11 ODFI Must Enter Origination Agreement with Originator
An ODFI must enter into an Origination Agreement with each Originator for which the ODFI will originate Entries. The Origination Agreement must include, at a minimum, each of the following:
(a) The Originator must authorize the ODFI to originate Entries on behalf of the Originator
to Receivers’ accounts;
(b) The Originator must agree to be bound by these Rules;
(c) The Originator must agree not to originate Entries that violate the laws of the United States;
(d) Any restrictions on the types of Entries that may be originated;
(e) The right of the ODFI to terminate or suspend the agreement for breach of these Rules in a manner that permits the ODFI to comply with these Rules; and,
(f) The right of the ODFI to audit the Originator’s compliance with the Origination Agreement and these Rules.
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