It's difficult to get seperation of duty in a small bank. I complete both the ACH audit and the risk assessment, with reports going to our Operations and Management committees and the Board. I'm not an AAP, but I have been with my small bank for about 100 years working within the ACH framework since about day one and have kept up with the rule changes. I have also been our Reg E Compliance Officer (I manage Bancard), and do a compliance review while I'm at it. The key for us is that I am not part of the daily ACH operations.
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Let's start at the very beginning; A very good place to start...