I was going to mention this before:
The ACH audit does not have to be done by internal audit! It has to be performed under the direction of the audit committee, audit manager, or senior level officer...or by a thrid pary reporting to the audit committee, BOD, or senior level officer.
We use PBS (Profession Bank Services) to conduct our audit. They use the FFIEC exam handbook and NACHA's ACH Rules. They look at the following:
The nature and characteristics of the bank's activities
Agreements with 3rd Party Providers
Agreements with members
Accounting and processing procedures
Funding and credit
Requirements as a RDFI
Requirements as a ODFI
Fed. Gov't ACH Payments
Compliance with Reg. E
Credit Entry Avail.
Account Statement description fields
Member identification procedures
All for about $2500- and they are qualified!
My opinion is mine only- not my employer's!