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#1290061 - 11/19/09 09:54 PM ACH agreements
Double U Offline
100 Club
Double U
Joined: Jul 2008
Posts: 219
BBN
Good afternoon all!

I was just reviewing some of our account agreements for ACH purposes with customers of our bank particularly those who we allow to send ACH(s) for payroll purposes. Could someone give me guidance on or point me in the direction on where I can find info. on what all should be included in the account agreement. Also are there certain disclosures we should present to the customers when they are given these agreements or any materials that we need to present them per NACHA. I am fairly new to compliance so any information is greatly appreciated. I am presuming these agreements to be in compliance because they were drawn up under our previous compliance officer who had several years of banking under their belt. I am just asking to gain some knowledge for myself because I need all the knowledge I can get a hold of. Thanks!

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Operations Compliance
#1290356 - 11/20/09 03:04 PM Re: ACH agreements Double U
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
Hmmm. First, are you talking about Commerical Customers. Are you an RDFI or ODFI or both? ACH is a very tricky area. We are a member of one of the Clearinghouse entities and NACHA. NACHA has quite the informative website. We use ACH agreements, for commerical customers, and the agreements are from NACHA. (They have a nice array of products). Your question is quite open ended. Let us know what you have researched first....

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#1290502 - 11/20/09 04:16 PM Re: ACH agreements Trees
Double U Offline
100 Club
Double U
Joined: Jul 2008
Posts: 219
BBN
Yes, this pertains to commercial customers. We're currently operate as both RDFI and ODFI. I have reviewed our account agreements, and they seem in-line with what NACHA proposes. I was wanting to know what all the customer receives after they have signed the agreement. Right now, we currently give the customer a copy of the agreement they signed along with a booklet of the NACHA rules. Is there anything else we should be giving our customers in regards to when they sign the agreement?

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#1291706 - 11/23/09 07:03 PM Re: ACH agreements Double U
kiemo Offline
Gold Star
kiemo
Joined: Jan 2009
Posts: 267
MidUS
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 ?)...

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