Management. These limits help manage financial exposure and minimize the risk of significant losses. 8. Return Handling Finding: Improperly managed ACH returns can lead to delays and potential compliance issues. Solution: Develop efficient return handling procedures in accordance with Section 3.8, RDFI’s Right to Transmit Return Entries. Ensure your team processes returns promptly to minimize delays and stay compliant. 9. Record Retention Finding: Not retaining ACH-related records for the required duration can cause complications during audits or compliance reviews. Solution: Implement a record retention policy that aligns with Subsection 1.4.1, Retention Requirement for Records of Entries. Ensure ACH transaction records are securely stored for at least six years and can be easily accessed when necessary. 10. ODFI Due Diligence Finding: Inadequate due diligence on Originators and Third-Party Senders can expose your organization to unnecessary risks. Solution: Conduct thorough due diligence on all Originators and Third-Party Senders as outlined in Subsection 2.2.3, ODFI Risk Management. We recommend this include background checks, creditworthiness assessments and ongoing monitoring to manage potential risks. By tackling these common ACH audit findings with actionable solutions, you’ll not only ensure compliance with the ACH Rules but also help streamline your ACH operations and safeguard your organization from potential risks. NEBRASKA INDEPENDENT BANKER 17
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