One more ACH question. In Appendix 8, Section 8.3 "Audit Requirement for ODFI's" of the 2007 Operating Rules, Item K states: "Ensure that Originators or Third-Party Senders are kept informed of and are in compliance with their obligations on a continuing basis", and then lists 19 requirements. How are other banks accomplishing this? Is it as simple as ordering the corporate rules version and providing that to our originating customers and their service providers? We only have a few customers that are originating their payroll via direct deposit, but the rules do not have a threshhold level. Any help will be appreciated.

We provide a copy of the rules book annually to our originators. We also send notification of any rule changes mid-year when applicable.

We do the same as glickstr.

I would do as above and also have them sign a receipt so that when you have your annual ACH audit you have documentation to show that you have fulfilled this.