COMPLIANCE and ACH SELF AUDIT - Bayer HFCU

34 Pages·2015·0.61 MB·English

by  Jennifer Gatts

COMPLIANCE
and
ACH SELF AUDIT
Presented By…
Jennifer Gatts, AAP
[email protected]
PAYMENTS CENTRAL, INC.
3380 Tremont Road
Columbus, OH 43221
Phone: [phone]
Fax: [phone]
www.paymentscentral.org
Objectives
• Learn the most common compliance
issues with regards to the ACH
Network
• Understand the ACH Annual Self Audit
Legal Framework
• NACHA Operating Rules
• Regulation E
• Uniform Commercial Code 4A
• 31 CFR Part 210
• OFAC
Compliance
Responsibilities
• The NACHA Operating Rules
apply to all commercial entries
and data transmitted through
one or more ACH Operator
• All participating DFIs agree to be
bound by the NACHA Operating
Rules
General Compliance
Requirements
• ACH Records
– Each RDFI and ODFI must retain records of
all entries transmitted through the ACH
Operator for six years
– Copies of these records must be made
available to customers, Participating DFIs
and ACH Operator upon request
– Any record may be retained electronically
• Accurately reflect the information
• Be capable of being accurately reproduced
ACH Self Audit - ODFI
• ACH Records Retention
– Attach a copy of one ACH Report which
show ACH entries transmitted to an ACH
Operator to the DFI. The entries contained
on the report must me dated at least 6 years
from the date this portion of the audit is
completed
– If electronic records are used, verify that the
electronic version of the record accurately
reflects the information contained within the
records in capable of being accurately
reproduced for later reference.
ACH Self Audit - RDFI
• ACH Records Retention
– Attach a copy of one ACH Report which
shows ACH entries transmitted from an
ACH Operator. The entries contained on
the report must be dated at least 6 years
from the date this portion of the audit it
complete.
– If electronic records are used, verify that the
electronic version of the record accurately
reflects the information contained within the
record and is capable of being accurately
reproduced for later reference.
General Compliance
Requirements
• ODFI Warranties
– Each entry has been authorized
– Credit entries are timely
– Debit entries are valid
– Entries conform to NACHA Operating Rules
– Authorizations have not been revoked
– ODFI has no knowledge that authorization has been
terminated by law
– Addenda complies with NACHA format
– Reclamations are valid and timely
– Agreements are in place with the Sending Points is
applicable
– Audit requirements have been met
– Source document has been properly handled (POP)
General Compliance
Requirements
• Originator’s Responsibilities
– Originator obtains Receiver's authorization
– Prenotes are sent according to the Rules
– Entries are not reinitiated unless within Rules
– NOCs are corrected within six banking days or prior to the next
live entry
– Reversing files/entries are submitted within five banking days of
the original settlement date of the erroneous or duplicate file
– POP receipts
– ARC and RCK entries
• Notice is given
– TEL entries
• Verify identity of Receiver
• Verify that routing numbers are valid
– WEB entries
• Commercially reasonable fraudulent transaction detection system
• Verify that routing numbers are valid
• Annual Audits