These policies reflect the components of the OCC-2006-39-ACH Risk Management Guidance. The ACH Management Policy addresses both RDFI and ODFI responsibilities for management consideration. Policy Addendum are included that relate to the various components of the guidance and serve to complement the overall ACH Management Policy. Example Addendum include Credit Risk, High-Risk Activities, Compliance Risk, Third-Party Service Providers and Direct Access to the ACH Operator, Transaction Risk and Information Technology. This CD serves as a valuable resource to ensure that you have the appropriate policies and procedures in place to limit your liability.