In reviewing the latest batch of our suspected Reg D violations, I came across a client who has ACH items that include a check number. Our system recognizes these as checks (part of the 3 allowable in a statement cycle) but they're also tagged as ACH, which would lead me to shuffle them in to the 6 allowable transactions. For documentary purposes, and for notifying the client, how would you classify these debits?
Thanks in advance for your help!
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It's called a nap, Susan Lucci!