Commercial cash management customer agreements generally work better when it comes time for examiner reviews when they are simple and concise. Make sure they bind the Originator (the commercial customer) to the ACH Rules, specify which SEC codes customer is allowed to originate into the ACH network, minimum security procedures expected, exposure limits, reversal entries, scheduling of file delivery. It doesn't hurt to update customer whenever new rules have been enacted as it's improbable they will keep up with changes throughout the year...it's good pr too.
(Are you providing them with copy of provisions of UCC 4A for commercial credits ?)...