I guess this is more of a survey question than anything else. How many of you as auditors are doing their banks annual ACH workbook? I know a lot of banks hire an outside firm to do theirs, but I want to know who else in your bank besides the auditor is doing it.

It probably would be based on if your institution had anyone else qualified to do an actual audit.

As the internal auditor I complete the annual ACH audit. I purchase the workbook from NACHA every year.

I have been doing it and purchasing the workbook, but instead of replacing our current Compliance/BSA/OFAC Officer I will be taking that on as well as my audit/ISO duties. I was trying to shift a few things around, but I may have to continue doing it.

I know our state payments association has an audit department that we could hire to perform the audit. I have not done so in the past but I have informed management that I may in the future as I have assumed additional responsibilities as well. Workbook or no,it is a time consuming audit, that is for sure.

Seems like that move jeopardizes your role as internal auditor?

I think their planc is to at least hire a firm that does complaince audits, so that does take that away. It is very time consuming. I say every year I am going to start it earlier, but somehow I don't!!!

We just had our outside ACH audit and were informed that we need to have a seperate ACH Policy. I guess this was new last year and we missed it. Does anyone have a sample policy they are willing to share to help give me a starting reference?

I believe I purchased our policy from NACHA and then customized it to our bank.

I complete the yearly audit as internal auditor and carry AAP credentials. To make the process easier, I do purchase a new ACH Audit Guide in CD form (UMACHA -regional ACH association)about every third year. Also, follow Article 8 in the ACH Rule Book. No way to shorten this one...