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Internal ACH Origination Based on Policy

Internal ACH Origination Based on Policy focuses on ACH origination activity that is governed by board-approved policy, including activity initiated by the ODFI when it acts as Originator. Whether origination is initiated internally or on behalf of other persons, policy defines what is permitted, restricted, or prohibited.

This course explains how policy defines what internal ACH activity is permitted, restricted, or prohibited, and why clarity matters. Learners examine common internal use cases, how authority is granted, and how internal origination differs from both customer-sponsored origination and exception handling.

The course emphasizes that “internal” does not mean informal or low risk. Through applied scenarios and decision points, the course reinforces how internal origination must still align with risk appetite, controls, settlement capacity, and documentation standards. Learners explore why policy boundaries exist, how internal activity can expand unintentionally, and when additional approval or policy review is required before proceeding.

Estimated learner time: 15•20 minutes, depending on pace and interaction with the scenario. This course is designed for ACH operations staff, treasury management teams, risk and compliance professionals, and others responsible for approving, executing, or overseeing ACH origination activity initiated by the financial institution.

This course is available exclusively to members of ePayResources.

Item Number - LMSM2613

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