[chimeracoder]

> You have to initiate a transfer at your bank, there's no way to use ACH independently as a consumer

That's actually not true - it appears that way because in practice ACH is only used in corner cases in the US, but it is absolutely possible.

> There's no confirmation step. If someone has your Account Number and Routing Number and does have a commerce setup, they can debit your account at any time.

...I have bad news for you about what the SEPA standards require!