Do we have the ability to implement internal same day ACH limits that are more conservative than NACHA's new $1,000,000 limit? If so, can internal limits differ by customer dependent on risk?

My guess is that we can limit same day ACH via disclosure and can allow for different limits per customer dependent on risk, but I would like to confirm. Thank you.

We limit ACH for all of our clients based on their expected and/or past usage during our underwriting and qualification to subscribe to the service.

I wouldn't allow someone with average balances of $20,000 and 10 ACH transactions a month of $500 to have a limit of $100,000.

Do you have an ACH policy that spells out how you will qualify individuals for ACH services?

That makes sense - thank you.