The company we hired to do our ACH audit has stated that we should be recording call backs made to customers for ACH and wires originated by the customer through online banking, and for wire requests received by phone. We currently do the call backs, we just don't record them.

Are any of you recording them, or have you had any experience with an auditor or examiner in regards to this issue?

We haven't had any issues with auditors or examiners regarding recording callbacks. We have had the risk auditors from our insurance company make recommendations to reduce potential incidents that may be excluded from coverage.

You should check the policy you have with the insurance company providing your bond coverage for electronic transfers. Our insurance company doesn’t require a recorded callback, although it is recommended.

The following must be documented if a callback is not recorded:
Name of employee performing the callback
Phone number used for the callback
Source or verification of the callback phone number
Name of person (requestor) confirming the transfer request
Date
Time

Callbacks are also based on risk; our deductible for a fraudulent wire transfer is $10,000 so we’re not performing callbacks on low dollar threshold/low risk transfers.

We document everything Freak does, except for the source of the callback number (we only use numbers that are on our system). However, we also record our conversations. We simply use a small device that taps into one of our normal phones and connected one of those small mp3 players that has a microphone-in jack. We start out every conversation by telling them that we are calling from a recorded line to verify their transaction. When the device is full, an officer dumps it onto one of our network drives (which is automatically backed up off-site).

We also document our callback to the customer. We reviewed our insurance policy and at one time, I think that it stated that we were required to have a recorded callback to the customer. We got with our insurance company and they had that stipulation changed in our policy. This is probably something you might want to check into.

all calls within our wire and ach department, as well as our call centers, are recorded...every single one.

Can you imagine going to court to defend a wire that your customer said they didn't authorize, and you say "judge we called them back and they said okay" and the judge says "can you play the recording?"...oops

We use a company wide recording system called (I think) PrairieFyre

And you test this system?

I only ask because "back in the day" I had a program that archived our web pages. It worked great until I went back to look at some javascript I'd used, and the files were not readable.