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Q.) If we require a direct deposit (ACH) payroll file to be pre-funded, do we need to set credit limits for that ACH customer?
A.) Yes! The ACH Rules require the ODFI to ensure that it can actively measure exposure limits when processing ACH debit and credit entries on behalf of its customers. But setting credit limits is just one step in limiting your liability as an ODFI. When an Origination file exceeds the limit set by the ODFI, strict procedures should be enforced and discussed with Originators prior to making a decision to allow a file to move forward (ACH Rules, OR6, Subsection 2.2.2.3, ODFI Risk Management).
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