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2019 Change of Address (Sort of): Audit Requirements

Amy Donaghue

By: Karen Sylvester, AAP, CAMS, CRCM, NCP, Director, Compliance Education

Effective January 1, 2019, the requirements for your annual ACH Rules Compliance Audit are moving from Appendix 8 of the ACH Rules (well, kind of). The voting membership of NACHA approved this move earlier last year, but don’t fear (or cheer) because the ACH Audit requirement is not going away.

I say “kind of” moved because, although the removal of Appendix 8 is noted in Supplement #2-2018 to the NACHA Operating Rules released last year and also printed in the front of the 2019 ACH Rules, you can still find Appendix 8 in the 2019 ACH Rules. But, technically you should now refer to the general audit requirement contained within Article One, Section 1.2.2 of the ACH Rules.

Your ACH Audit must still be done annually by December 31, but this change lends itself to a consolidation of the general audit obligations within the rules by combining the core audit obligations along with the general administrative requirements for completion of the audit. The thought behind this change is that it will allow the information to be contained in a single topic area, lead to a more efficient process and minimize the potential for user error.

The impact will also allow your organization to change or enhance your current methodologies for conducting your audit. Currently, many users utilize Appendix 8 as a checklist for conducting their audit. However, users should be aware of the limitations or missing criteria as there is additional language within the Rules that should also be considered in a risk-based approach to your audit. Many financial institutions and third-parties may be utilizing a workbook or guide to facilitate their general annual audit and are unaware that more robust educational resources exist in the form of audit guidelines.

Whether your financial institution completes your ACH Rules Compliance Audit internally or has an external party such as EPCOR facilitate your audit, EPCOR will continue to have an ACH Audit Workbook available. You can expect to see enhancements to the workbook to facilitate a greater audit experience while removing duplicate audit criteria. EPCOR will also be hosting one-day Navigating Your 2019 ACH Audit seminars in six different locations this June. Stay tuned to News You Can Use for more information, coming soon!