ACH Gurus...need help

I need help with ACH please. We have some businesses that are not set up as ACH originators who have reoccuring monthly ACH payments that they have set up to transfer externally to other parties. Isn't this the definition of an ACH originator and shouldn't we have an ACH agreement with the originator and be monitoring exposure limits?

We also have some ACH origiantors who have set up reoccuring external ACH transfers to/from other parties outside of their normal ACH origination. Our current ACH origination doesn't allow for reoccuring payments so it is set up in a separate system. Therefore, the reoccuring payments are not being montiored with the daily exposure limits because the reoccuring payments are not inlcuded in the monitoring.

I don't think this is within the rules but please let me know if I'm wrong. thanks!

I would have to say that they are an ACH originator if your bank is originating the ACH transaction. In other words, if they just have reoccuring ACH transactions on their account but another bank is initiating the ACH transaction (i.e., DISH payments) then no they are not an ACH Originator.

In our bank we have one method for ACH origination and that is through our online banking system. We have to grant them access to this (after agreements are signed) and we have all kinds of controls in place and operational procedures.

If you have two methods for your business customers to send you ACH files for processing then you should have two sets of procedures for this.