Under NACHA Operating Rules, an Originating Depository Financial Institution (ODFI) that originates ACH debits is required to conduct which type of ongoing monitoring of its originators?
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A
Annual PCI DSS audits of originator systems
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B
Risk-based monitoring of originator return rates and transaction patterns
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C
Monthly OFAC sanctions screening of all ACH batches
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D
Quarterly reviews of originator interchange revenue