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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

From Data to Decisions ACH Origination focuses on how ODFIs move from information gathering to informed action when overseeing ACH origination activity. Data points, alerts, and reports provide inputs, but they do not resolve risk without analysis and judgment.

This course explains how ODFIs evaluate data from monitoring tools, reports, and required databases in context rather than in isolation. Learners examine why individual metrics may appear benign, how multiple indicators together can form a meaningful signal, and why timing and persistence matter when assessing risk. The course reinforces that data supports decisions but does not replace responsibility.

Through applied examples and decision scenarios, the course demonstrates how ODFIs determine appropriate responses, including continued monitoring, additional inquiry, escalation, or restriction of activity. Learners also explore the importance of documentation and consistency when translating observations into defensible decisions.

Estimated learner time: 15•20 minutes, depending on pace and interaction with the scenario and knowledge checks. This course is designed for ACH operations staff, risk and compliance professionals, and others responsible for interpreting origination data, exercising judgment, and determining when ACH origination activity requires action.

This course is available exclusively to members of ePayResources.

Item Number - LMSM2615

Evaluate Risks & Controls in ACH Origination focuses on how ODFIs assess whether their existing controls continue to reduce risk as ACH origination activity evolves. Once an origination partner is approved, the work shifts from deciding whether to originate to confirming that controls still align with real-world activity.

This course explains how exposure limits, file-level controls, behavioral monitoring, and operational procedures work together to manage risk. Learners examine why controls designed for earlier conditions may lose effectiveness as volumes increase, products expand, or origination behavior changes—even when no single metric appears alarming on its own.

Through applied examples and knowledge checks, the course reinforces that unchanged controls are not a neutral outcome. Leaving limits, procedures, or monitoring logic in place while activity evolves is a decision that carries accountability. Learners also explore how cross-functional involvement—from operations and IT to BSA/AML and compliance—supports effective control evaluation.

Estimated learner time: 15•20 minutes, depending on pace and interaction with the knowledge check. This course is designed for ACH operations staff, risk and compliance professionals, and others responsible for monitoring origination activity, evaluating control effectiveness, and ensuring that ACH programs remain aligned with policy, capacity, and risk appetite.

This course is available exclusively to members of ePayResources.

Item Number - LMSM2604

Ending ACH Origination Relationships focuses on how ODFIs terminate ACH origination activity when risk, performance, or alignment with policy changes. Ending a relationship is not a failure of oversight. It is a governance decision that protects the ODFI, the Network, and other participants.

This course explains the circumstances that lead to offboarding decisions, including sustained performance issues, unmanaged risk, changes in business model, or failure to meet contractual or policy expectations. Learners examine how termination decisions differ from temporary restrictions and why clarity around authority, timing, and communication matters.

Through applied examples and decision scenarios, the course reinforces how ODFIs plan and execute offboarding in a way that limits exposure, supports orderly wind-down, and preserves documentation. Learners also explore why origination activity must stop before agreements are terminated and how settlement, returns, and residual risk are managed during the transition.

Estimated learner time: 15•20 minutes, depending on pace and interaction with the scenario. This course is designed for ACH operations staff, risk and compliance professionals, and others responsible for managing origination risk, enforcing policy boundaries, and executing termination decisions within an ODFI’s origination program.

This course is available exclusively to members of ePayResources.

Item Number - LMSM2619

Education, Monitoring, and Fire Drills for ACH Origination focuses on how ODFIs maintain operational readiness after origination begins. Policies, procedures, and controls lose effectiveness when staff knowledge fades, monitoring becomes routine, or response plans go untested.

This course explains how ongoing education supports consistent decision-making, how monitoring reinforces expectations established during onboarding and underwriting, and why periodic fire drills help teams respond effectively when issues arise. Learners examine how changes in origination activity, staffing, systems, or third-party relationships increase the need for refresher training and readiness testing.

Through applied examples and scenario-based discussions, the course reinforces that fire drills are not indicators of failure. They are deliberate exercises that expose gaps, clarify roles, and strengthen response coordination before real events occur. Learners also explore how education, monitoring, and preparedness work together to support timely escalation and effective risk management.

Estimated learner time: 15•20 minutes, depending on pace and interaction with the scenario. This course is designed for ACH operations staff, risk and compliance professionals, and others responsible for maintaining ongoing readiness and oversight within an ODFI’s ACH origination program.

This course is available exclusively to members of ePayResources.

Item Number - LMSM2618