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ACH Origination Limit Subject to Legal Limit?

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Is a customer's ACH origination limit subject to the legal lending limit?

The ACH origination limit is a risk-mitigation control designed to prevent loss if an Originator doesn't have sufficient funds to pay for outgoing ACH credits or might have outgoing ACH debits returned. Often, banks are guided in establishing such a limit by various measures of an Originator's creditworthiness, and might even decide to cap the limit based on actual credit outstanding and whatever legal lending limit applies.

However, lending limits (legal, regulatory or institution-imposed) are not directly related to ACH origination limits, since ACH origination is not considered an extension of credit, per se.

First published on 11/28/11

First published on 11/28/2011

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