Is Your Financial Institution Its Own Automated Clearing House (ACH) Originator?

Financial Institutions

July 01, 2012
by Nicole Meinhardt, CPA

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Nicole Meinhardt Nicole Meinhardt, CPA
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When a financial institution originates entries as the originator, the institution is subject to the same ACH Rules as any other originator. The entries, files, authorization agreements, etc. associated with the institution’s origination of such entries are not required to be included in the annual ACH audit required by Appendix 8 of the ACH Rules. However, there can be significant rule violations and risk in these areas; therefore, entries for which the financial institution is its own originator should be included in either the annual ACH audit or other internal audit program.

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