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Originator Agreements

ACH Originator/Third Party Sender Agreements

Sam Davidson, Davidson Firm PLLC


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Designed For:

Fintech companies that lack state money transition licenses and facilitate movement of funds through ACH and by US banks on behalf of their platform users.



This Screen was built to help fintechs without state money transition licenses that play any role in an ACH file to protect itself against inadvertently violating state money transmitter laws and subjecting itself to overly aggressive ODFI terms. It also helps ensure that key NACHA requirements are met. You can copy and paste these standards and questions into your own screens and modify as you see fit.


Limitations, Assumptions, Details:

This Screen has been validated against at least 7 contracts. All 10 standards have performed at 100% accuracy. This screen should be used with a lawyer, not in replacement of a lawyer. Neither Screens nor any screen author is or will provide you with legal advice. AI accuracy rates vary based on a number of factors so always double check all AI predictions.


Sam Davidson

Sam Davidson

Sam Davidson is a seasoned fintech attorney, general counsel and chief compliance officer with years of in-house operational experience. His practical, business-friendly approach, combined with extensive legal knowledge, enables him to offer entrepreneurial and pragmatic counsel to his clients. He has worked with fintech startups, banks, trusts and financial institutions at various growth stages in the U.S., Europe, and South America.

Sam is particularly valuable in understanding and addressing the diverse legal challenges in the financial services sector. He provides counsel on a range of issues, including:


  • Customized regulatory strategies for fintech firms, trust companies, banks, and credit unions.
  • Managing transactions involving regulated institutions.
  • Navigating through federal and state financial service regulations.
  • Handling investigations, examinations, and enforcement matters with banking agencies.
  • Offering general counsel services on commercial agreements, labor and employment issues, and corporate affairs.

Additionally, Sam is skilled in creating and implementing compliance, fraud prevention, and governance protocols. These strategies are designed to efficiently maneuver through the complexities of federal, state and international regulations, aiding clients in achieving their business objectives while staying compliant. His combination of legal acumen and operational experience makes him an invaluable asset in the fintech legal arena.

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