4061 - ACH Originator

The ESU sends electronic payments through the ACH (Automated Clearing House) Network such as payroll direct deposits and/or vendor payments. Because of these payments, the ESU is classified as an ACH Originator. As an ACH Originator, the ESU complies with the National Automated Clearing House Association (NACHA) Operating Rules which govern the ACH Network. The ESU’s bank requires compliance with the Rules as a condition of the ESU’s ability to send ACH Payments.

Responsibilities. The ESU follows all terms of its Originating Depository Financial Institution/Originator Agreement with its bank. The ESU obtains a written authorization before sending any ACH payment. The ESU meets all processing deadlines set by the bank and NACHA. The ESU gives authorization records to the bank upon request within NACHA’s required timeframes. The ESU keeps all sensitive banking information secure. When the ESU receives a Notification of Change, it updates the payment record before the next ACH transaction. When the ESU receives a return due to an error or unauthorized activity, it stops all related subsequent payments until instructions are received from the Bank. The ESU keeps its computer systems and network secure in line with its bank agreement. The ESU uses procedures to spot unauthorized payments. All employees with ACH duties will complete training, if required by the Bank or NACHA, and respond to audit requests. The ESU will implement internal controls and procedures to mitigate errors and risk of unauthorized ACH entries.

Fraud Monitoring. The ESU reviews ACH transactions for unusual patterns or amounts before submitting each file. If the ESU suspects an error or unauthorized ACH transaction, the ESU will: determine whether the problem is fraud, a scam, or an internal error; notify the bank right away; contact law enforcement if needed; and stop all related future ACH transactions.

Employee Training. All employees with ACH duties will complete any ACH origination training required by the ESU’s designated bank(s).

Adopted on: August 10, 2026

Policy 4001

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Policy 4060

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