Comments Automated Clearing House Growth in an International Marketplace: the Increased Flexibility of Electronic Funds Transfer and Its Impact on the Minimum Contacts Test

One of the most rapidly growing technologies in the cash management industry is the Automated Clearing House ("ACH") system.' The ACH system is the electronic equivalent to the paper check processing system.' The primary benefits of the system, for both banks and their customers, result from reducing the processing time and costs associated with paper check systems! Although other types of electronic funds transfer devices are more common, the ACH system is experiencing the fastest growth rate.4 The growth of cash management technology has become more significant as nations have become more economically