ACH Compliance Audits

The National Automated Clearinghouse Association (NACHA) mandates an annual audit of a Credit Union’s ACH operations by December 31. The purpose is to demonstrate to regulators that the Credit Union has implemented controls, checks, and balances for automated clearing house (ACH) payments.

Below are a few of the more frequent problems we see in ACH audits. These comprise only a few of the many checks we incorporate into our assessments.

Financial Institution ACH Policy

A Credit Union facilitates a smooth ACH audit process by keeping a comprehensible, routinely updated, and detailed ACH policy.

Without a policy outlined for employees, ACH staff won’t have available guidance—and mistakes and confusion will take time and effort away from processing transactions.

Often, Credit Unions copy ACH policies from other institutions or use the NACHA ACH manual for a policy. These are great places to start when creating a policy from scratch. However, Credit Unions must edit those copied policies for their own institution to be truly useful.

Multiple Regulations Applicable to ACH Transactions

ACH transactions are largely regulated by NACHA rules, but there are other federal regulations that must be applied, such as:

          • E-Sign Act
          • Funds Availability (Reg. CC)
          • Electronic Funds Transfer Act (EFTA)
          • Bank Secrecy Act (BSA)

There can be significant consequences to these additional federal regulations—thus, they should be reflected in the Credit Union’s ACH policy.

Unauthorized ACH Debits

Often, we find conflicts between stop payment returns and unauthorized debits—discovered through the review of disclosures, forms, and timeframes given to Credit Union members.

With an ACH compliance audit, the auditor can find these errors and use these as opportunities to inform and educate staff while making recommendations for policy updates. Cleaner internal guidelines and updated processes for staff can support less confusion and fewer errors for future transactions.


ACH Audit Looks at Manual Processes Too

ACH transactions involve both manual processes and automated processes. The manual processes performed by the Credit Union personnel—including ACH setup, input, and maintenance—are all subject to error and need regular review. Some of the manual processing could include:

          • Processing returns
          • Posting to accounts
          • Transmitting to the ACH Operator
          • Ensuring that agreements are obtained
          • Monitoring origination files prior to transmission

Annual ACH Audits for Credit Unions

At Griffin & Furman, our ACH compliance audit services contribute to the quality of your Credit Union’s ACH services. We test against the most updated regulations, identify potential risks, review internal controls, and recommend process improvements.

If you would like to talk about your Credit Union ACH audit, please give us a call.