Are You ACH Rules Compliance Audit Ready?

Amy Donaghue

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

After many years in the industry, many of those working in a financial institution, I have never, ever thought of the ACH Compliance Audit as something I looked forward to completing. But, just like any other item on the to-do list, going in prepared and with a positive attitude makes all the difference!

The payments industry used to look to Appendix 8 of the Rules as our guide through the ACH audit. And, since it was removed a few years ago, the ACH audit seems to be more daunting than ever before. However, the removal of Appendix 8 allows a financial institution or a Third-Party Sender to do a more complete audit of the areas of ACH that it actually participates in and look at ACH activity from a risk perspective instead of just something that happens.

There are many guides available to financial institutions to help you walk through the audit process including the ACH Audit Workbook, which is available on the EPCOR website. But, while choosing your guide is just the first step, you must then decide who should perform your ACH Compliance Audit. This annual task is not for just anyone. The person or people conducting your annual audit should have a working knowledge of ACH and the criteria behind the audit.

As a traditional trainer here at EPCOR and someone who has spent years working in a financial institution, I find understanding the what and the why behind the audit criteria is essential. For the past few years, I have been conducting a training session called Navigating the ACH Audit and each year I hear more and more members saying we need more explanation and understanding before we begin to dive into our ACH Audit. We have taken your concerns to heart and decided to enhance the Navigating the ACH Audit class. This enhancement includes more explanation and a deeper dive into those painful topics including policies and procedures, stop payments and information included in your organization’s final report. Every year new rules are added, but rarely does anyone talk about how to audit the changes. So, some other topics added to the session include Same Day ACH, the ACH Contact Registry and the Meaningful Modernization Rules.

Whether conducting the ACH Audit yourself or having someone internal or external complete the audit, this session will help guide you through the process and deepen your understanding of what to look at or what they are looking for in the process. The ACH Audit is only as helpful as the person(s) reviewing the information.

If the thought of conducting your ACH Compliance Audit makes your head spin, we’ve got you covered! Consider having your service conducted by our team of experts! Reach out to us at audit@epcor.org for a no-obligation quote. Or, if you’re going the DIY route, check out our newly updated ACH Audit Workbook or attend our Navigating the ACH Audit educational event which is comprised of two sessions, lasting two hours each on August 5 and 6. Here, all the new ACH Rules updates and more will be discussed. I hope to see you then!