We are reviewing our ACH and Loan Policies.

The question arose as to whether or not ACH Exposures should be included in Lending Limits?

Thanks!

We do

I think you have to consider several factors. Are ACH files only generated off collected funds and what time of files are being generated? For us they are included in the lending limits.

every one of our originators has an exposure limit, some we require to be prefund customers (pay first or file is held), others we can allow to originate regardless of account balance as it is tied to a LOC, others may have no LOC with us but depending on their credit rating can have a high exposure limit that we allow them to originate up to.

we have a fairly detailed policy regarding ACH exposure, and it is a credit policy, but it is separate from our normal credit policy.