Is anyone aware of any “legal and financial penalties” with respect to having an non-compliant or incomplete ACH agreement? We acquired a FI last year and an audit determined that we needed to repaper all ACH clients with the our FI agreement. We did not feel like that was necessary at the time and thought the acquired FI's agreement would suffice. Has anyone had this issue before? Is anyone aware of any guidance on this topic?

the agreements within M&A activity should cover, that is my experience. if you have to get new agreements from a customer for a service in the future, having them complete for all services is always a good practice. but not solely due to merger. you may want to seek your regulators opinion and look to see if your state has guidance on this.

Thank you HappyGilmore!