I have recently joined the internal audit department of a bank holding company. The previous internal auditor started the 2009 ACH Audit in November, but didn't complete it. I have now been charged with getting it done. Obviously, the December 1 deadline has been missed. To complicate the situation, the ACH process was consolidated under the holding company from 5 invidual banks at the end of 2009.
I believe that the audit needs to be completed. However, I am unsure about "when" to test. Should I test transactions prior to December 1? I know that the consolidation resulted in several procedural changes and am afraid that it will be inefficient to test prior to the consolidation. Any thoughts?