ACH

Do you allow your consumer customers to send an ACH credit from their account to an account owned by them at another institution?

Do you allow your consumer customers to send an ACH credit from their account to someone other than him/herself at another institution?

Do you allow your consumer customers to send an ACH debit from their account to an account owned by them at another institution?

Do you allow your consumer customers to send an ACH debit from their account to someone other than him/herself at another institution?

Do you require ACH Origination agreements that fully comply with the ACH rules if you allow any of the above scenarios? Thanks for your input.

Why should the answer not be yes to all of them if you choose to offer such a service?

I agree with your comment and we are offering all of those. My follow up question is the type of ACH origination agreement that is required in each instance. Our banks are not always obtaining ACH origination agreements with one off originators (who are only originating one entry a month or two entries a month). They find it to be overkill but I'm recommending that they have to have some type of origination agreement with all originators regardless of the frequency of ACH origination. Thoughts? Thanks.

Whoever "they" are needs to review the NACHA requirements.

SUBSECTION 2.2.2 ODFI Agreement with Originator, Third Party Sender or Sending Point
SUBSECTION 2.2.2.1 ODFI Must Enter Origination Agreement with Originator
An ODFI must enter into an Origination Agreement with each Originator for which the ODFI will originate Entries. The Origination Agreement must include, at a minimum, each of the following:
(a) The Originator must authorize the ODFI to originate Entries on behalf of the Originator
to Receivers’ accounts;
(b) The Originator must agree to be bound by these Rules;
(c) The Originator must agree not to originate Entries that violate the laws of the United States;
(d) Any restrictions on the types of Entries that may be originated;
(e) The right of the ODFI to terminate or suspend the agreement for breach of these Rules in a manner that permits the ODFI to comply with these Rules; and,
(f) The right of the ODFI to audit the Originator’s compliance with the Origination Agreement and these Rules.