(C) Risk mitigation schemes in ACH To operate ACH with risk reduction methods, sender net debit cap and maximum transfer amount are implemented in ACH. The policy18 to guarantee the net deficit of a debtor will be considered separately by CBM, which will not be managed by the collateral management functions of CBM-NET due to a request from CBM (the collateral management functions of CBM-NET Phase 2 will not manage collateral for ACH even if CBM start to reserve the collateral for ACH19). In addition, the establishment of Policy for Net Debit Cap, sharing with FIs and parameter setting on the system must be completed before go-live.  ACH clearing process, which automatically calculates net debit position of a debtor bank and checks whether the net debit position surpasses sender net debit cap or not, also works all day except the system maintenance period.  Sender net debit cap can be changed all day except the system maintenance period. 18 The selection of method (survivors pay arrangement or defaulters pay arrangement), contribution and management method of collateral, establishment of liquidity provider (bank to temporary reimburse deficit amount by default banks), and method to dispose collateral should be considered. 19 In case of managing the collateral reserve (collateral appointed and reserved from total collateral for RTGS) for ACH in future, management body of the collateral, the method (or the system) to manage with sender net debit cap, and collateral disposing process in case of deficit bank’s default. 46