We have been an RDFI to this point, with an applicable ACH Receipt policy in place.

We are becoming an ODFI. Is it advisable to have a separate ACH Origination policy, or does it make more sense to combine the two to create one overall all encompassing ACH policy?

Thoughts one way or another?

Also, looking at the potential customers and their business experience we tend to target with business banking and allowing them to have ACH originationa abilities (mostly for payrolls and such), what are thoughts on having business owners being a Guarantor on a business checking account (pending we have done our diligence and proven assets and such), vs requiring them to tie up said assets in another related deposit account. Currently we are looking at having the business maintain a deposit account as collateral equal to their ACH exposure, but this seems anti-business friendly. Could a Guarantor Agreement on a deposit account hold enough bite?

I would combine into one since ACH is the overall function. Check out the NACHA website. We got a good origination book from them and it was used to write policy/procedures. There were a lot of good template forms too and I think it was relatively cheap.

I agree with audit guy(?).