Our ACH Policy has the following statement:

ACH debit transactions will not be accepted for accounts that the Bank has classified as accounts where debit activity is limited to six entries under the Federal Regulation D and the ACH debit entry represents the seventh debit entry.

So, we have been returning the 7th ACH entry.

The sample ACH policy provided on the bankers tools has the same statement. We were recently questioned about this during our deposit audit. Why is the ACH entry not accepted if it represents the 7th debit entry?

can someone shine the light here for me?

Thanks,

I would ask your auditor. Reg D gives you the option of rejecting items that exceed transaction limitations or adopting a process to honor transactions and notify customers that exceed limits, as well as either close or reclassify accounts that exceed limits more than 3 times in a rolling 12 month period.

Your auditors may be more familiar with the second option since it is the one that most banks use.

Are these internal auditors, outsourced third party? If the latter, maybe you need to vet them at a little more...