Our examiners included a recommendation on our last exam to require them to have dedicated accounts. Since I had previously pitched that unsuccessfully I was happy they did, especially since while we were doing all that we added a monitoring fee which got rid of a couple. Dedicated account makes the periodic monitoring pretty easy. ACH credits in, cash withdrawn to stock the ATM. Closed loop, all in balance... Ironic we're getting a fee now when the monitoring got easier.