There are just a couple of months before your 2022 ACH Compliance Audit is due. The purpose of this annual audit is to ensure the controls you have in place related to your ACH payment processing are working.
While the ACH Rules require an audit to be conducted annually, they do not prescribe how to audit or specifically what to audit. However, Chapter 56 within the Operating Guidelines provides recommendations and guidance on key areas to be considered and highlights the most critical components of an audit of compliance with the ACH Rules. Additionally, it suggests conducting a broader examination of ACH operations (i.e., beyond the ACH Rules), including compliance with policies and procedures (e.g., ACH policy, risk management policy, business continuity) as well as compliance with regulations governing ACH payments, such as OFAC, 31 CFR 210, Regulation E, etc.
If planning to conduct your audit internally, here are some high-level tasks to do in preparation:
- Set a date and establish contact with the primary individual responsible for providing the documentation that will be required for the audit.
- Review your institution’s ACH Audit Policy, which may be a separate policy or included as part of an overall audit policy.
- Determine sampling dates by selecting random dates (Monday through Friday, watch out for holidays) and pinpoint active dates (e.g., the first, middle and end of month).
- Ask for a list of personnel responsible for ACH processing, which will be used for interview purposes, and request documented procedures and reports. A checklist of the items you will need from Operations is recommended and be sure to give them 2-4 weeks to retrieve documentation.
- Determine the audit method to use (e.g., interviews, sampling, testing).
- Review general audit controls, including organizational controls, training programs, operating procedures, risk controls, and physical security.
- Get a copy of the 2022 ACH Rules and Supplements #1-2022 and #2-2022.
- Consider purchasing EPCOR’s ACH Audit Workbook, which is designed to guide you through the process.
- Watch our ACH Audit Like a Pro recording, where EPCOR’s Audit Team dishes out their closely held secrets and top ACH Compliance Audit findings so you can avoid them in 2023.
While preparing for your audit this year, remember we’re here to help implement your audit findings (from this year or last) if you need it! EPCOR’s payments experts can also help you identify ways to bring in new revenue, reduce risk, maximize efficiencies and more! Schedule your Audit or Risk Assessment for Q1 so you can have a clearer vision of your goals for the rest of 2023.