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Q.) Do we need to comply with the ODFI Risk Management rules if we prefund our ACH Originators?
A.) Yes, the Rules do not make exception based on how and when ACH files are funded. As outlined in the ACH Rules, Subsection 2.2.2, ODFI Risk Management, ODFIs must perform due diligence on all Originators and:
- assess the nature of the ACH activity and the risks it presents;
- establish, implement, and periodically review an exposure limit for the Originator; and
- establish and implement procedures to:
- monitor the Originator’s origination and return activity across multiple Settlement Dates;
- enforce restrictions on the types of entries originated; and
- enforce the exposure limit
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