FMSI www.fmsiconsulting.com 913.955.3355 FMSI is a small business founded and located in Kansas, specializing in assisting community banks to succeed, a mission consistent with core CBA values. We have partnered with community banks for nearly 25-years providing core advisory services including asset/ liability, investment, and liquidity management. FMSI advisors actively assess market conditions and bank balance sheets of different size, mix, and capital levels. Market conditions are constantly changing presenting opportunities and challenges for CBA member banks. Interest rates are increasing for the first time in nearly a decade and now is a perfect time to partner with a trusted, industry leader. Establishing an FMSI relationship provides confidence your bank is optimizing the balance sheet, deploying necessary strategies, maximizing profitability, and managing balance sheet risks. FMSI is a Kansas CBA Endorsed Provider aside, it has been EPCOR’s audit recommendation for the TPS to add the required provisions as soon as possible. We often suggest creating an “ACH Addendum” that can be added to the existing agreements without a complete repapering project. Notable Mention Findings Other less frequently cited audit findings still worth noting for TPSs include: • Failure to establish exposure limits; • Failure to act on Notifications of Change (NOCs); • Incorrect assignment of Standard Entry Class (SEC) Codes; • Inadequate authorization language; • Lack of monitoring of Originator Return Rates; and • Best practice suggestions for the establishment of a formal ACH Management Policy and the establishment of procedures to acquire authorizations or other ACHrelated documents from Originators and/or Nested TPSs. If you work for an ODFI and are reading this article, I hope this has given you some insight into deficiencies some of your TPSs may have regarding ACH Rules compliance. It is highly recommended that you request confirmation of an annual ACH Compliance Audit from your TPS client and even go further to request the ACH audit report so you can supplement your due diligence process and see what compliance issues your TPS may be experiencing. The information presented may highlight some ACH compliance topics/issues that you aren’t aware your TPS needed to follow. If you’re a TPS, I hope this article has been thought-provoking and opened your eyes to potential issues and areas to consider making changes to ensure you are compliant with the ACH Rules. Just remember your financial institution is your ally. If you feel like you need additional education or guidance from them, reach out and work together to come up with a solution that works for everyone. Matthew travels throughout EPCOR’s footprint to conduct consulting, audit and risk assessment engagements related to ACH, Wire Transfer, Third-Party and other paymentsrelated services. As part of these services, Matthew provides recommendations related to compliance with ACH Rules, payments-related regulations and regulatory guidance. Matthew also provides education and shares best practices with financial institutions and Third-Party Senders to support their efforts towards maintaining compliance, improving operational processes and mitigating risk and fraud. Matthew graduated from the University of Kentucky in 1997 with a Bachelor of Science in Accounting and Management. Matthew has 23 years of professional experience, including 15 years in the financial services industry with a strong emphasis in audit, ACH and financial analysis. 21 In Touch
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