TOP 10 Auditing ACH transactions is an essential part of ensuring compliance and maintaining the integrity of your organization’s payments. It can often feel overwhelming, but fear not! EPCOR’s expert team is here to transform that chaos into a streamlined process. The following are the top 10 common ACH audit findings with practical solutions to tackle them. 1. Annual ACH Compliance Audits Finding: Neglecting to complete your annual ACH Compliance Audit could put your organization at risk of non-compliance with the ACH Rules. Solution: Schedule your annual ACH Compliance Audit ahead of the Dec. 31 deadline as required by Subsection 1.2.2.1, General Audit Requirements. Ensure that audit reports are securely stored for at least six years, as required by Subsection 1.2.2.2, Proof of Completion of Audit. 2. Periodic Risk Assessments Finding: Skipping regular ACH Risk Assessments could leave your organization unaware of potential emerging risks. Solution: Perform an ACH Risk Assessment periodically to identify and mitigate potential risks in accordance with Subsection 1.2.4, Risk Assessments. We recommend you complete a risk assessment every 12-18 months. Develop a comprehensive risk management program that addresses the risks of your ACH activities — such as operational, credit and fraud risks — to ensure ongoing compliance. ACH AUDIT FINDINGS OF 2024 By Trista WOOLSTON, AAP, APRP, EPCOR Electronic Payments Core of Knowledge 3. Security Policies and Procedures Finding: Outdated or inadequate security policies may leave ACH data vulnerable to breaches or cyber threats. Solution: Develop and regularly update security policies in line with Section 1.6, Security Requirements. Stay ahead of emerging threats by adapting your policies to meet the latest industry standards and ensure the safety of ACH transactions. 4. Origination Agreements Finding: Missing or incomplete language in origination agreements can lead to compliance gaps or operational challenges. Solution: Review your origination agreements to ensure they include all necessary provisions required by Subsection 2.2.2.1, ODFI Must Enter Origination Agreement with Originator and Subsection 2.2.2.2, ODFI Must Enter Origination Agreement with Third-Party Sender. This includes risk management clauses, indemnification language and proper authorizations. Secure signed copies of these agreements for your records. 5. Training and Education Finding: The ACH Rules are complex! Without adequate training, employees may lack the necessary understanding of ACH operations and compliance obligations. Solution: Implement an ongoing ACH training program so your staff can receive regular updates on the latest ACH requirements. 6. Incoming NOCs and Correcting NOCs Finding: Improper handling of Notifications of Change (NOCs) can result in inaccurate data and compliance issues. Solution: Establish clear procedures for managing incoming NOCs and instructing Originators to make corrections in a timely manner, ensuring compliance with Section 2.12, Notifications of Change. Originators must make the changes specified in the NOC or corrected NOC within six banking days of receipt of the NOC information or prior to initiating another Entry to the Receiver’s account, whichever is later. 7. Exposure Limits Finding: Not setting or reviewing exposure limits can leave your organization vulnerable to financial risks. Solution: Define and regularly review exposure limits based on your organization’s risk profile, as required by Subsection 2.2.3, ODFI Risk 16 NEBRASKA INDEPENDENT BANKER
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