How do you define 'continuing basis?'

OK BOLers it's that time of year again...NACHA!

So how does your bank define 'continuing basis,' with respect to how often Originators must be kept informed of their responsibilities. I'm thinking annually makes the most sense.

I would say annually as well. If you are reading this in your bank ACH policy, you should reccomend that policy be changed to read annually. "On a continual basis" is not very auditable.

'Continuing basis' is actually the language that the NACHA book uses. That's where my question stemmed from.

I would agree with annually. If the rules change, they need to be notified and usually they are with the annual updated rule book.

Do you provide the rule book to your originators? The big one or the corporate one? Do you charge them? And do you give them any explanation/instruction when you provide it to them?

Audit Guy - - I worded it as "at least annually" in my report.

I would love to know what others are doing for training, too. And how is the training documented?

I didn't find any originators in disobedience of the rules, but.... I am once again listing lack of evidence of training as an audit finding.