Ach Audits
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General Audit Requirements
Each Participating DFI, and any third-party service provider that provides ACH services to the DFI, shall, in accordance with standard auditing procedures, conduct an internal or external audit of compliance with provisions of the ACH rules in accordance with the requirements of Appendix Eight. These audit provisions do not prescribe a specific methodology to be used for the completion of an audit but identify key rule provisions that should be examined during the audit process. Such annual audit shall be conducted under these Rule Compliance Audit Requirements no later than December 1 of each year. The Participating DFI must retain proof that they have completed an audit of compliance in accordance with these rules. Documentation supporting the completion of an audit must be (1) retained for a period of six years from the date of the audit, and (2) provided to the National Association upon request.
SUGGESTED AUDIT PROCEDURES:
Review past year(s) audit report to verify completion and timeliness, and retain documentation showing results of past audits.
___________________________________________________________________________________________________________________________________________________________________________________________________Note exceptions from past year(s) and inquire about follow-up work by staff.
Inquire about any third-party ACH service providers (such as DP vendors, Corporate Credit Unions, or payroll processors, etc), and review and retain any documentation concerning the audits completed by these providers.
COMMENTS, RECOMMENDATIONS, AND EXCEPTIONS:
Requirements Related to Receiving ACH Entries
Verify that records of entries, including return and adjustment entries, transmitted from or to an ACH Operator are retained for six years from the date the entry was transmitted. Verify that a printout or reproduction of the information relating to the entry can be provided to the Participating DFI’s customer or any other Participating DFI or ACH Operator that originated, transmitted, or received the entry.
SUGGESTED AUDIT PROCEDURES:
Question staff on procedures for retaining all ACH records for the past six years.
Review past records for complete data on all received and returned entries. Determine if all the various fields from the ACH files are reflected on the reports, including return and NOC codes on exception handling reports. Retain paper copies of the reports reviewed.
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COMMENTS, RECOMMENDATIONS, AND EXCEPTIONS:
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