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#1997422 - 02/20/15 09:51 PM oversight of ACH compliance
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Who has this responsibility in your community bank? Compliance Department? C.O.O.? I.S.O.? This person keeps up on changes and prepares risk assessments, etc.

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General Discussion
#1997427 - 02/20/15 10:02 PM Re: oversight of ACH compliance [Re: Trees]
kiemo Offline
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kiemo
Joined: Jan 2009
Posts: 267
MidUS
Electronic Banking Manager with insight from the Compliance Officer completes a comprehensive risk assessment. The Internal Auditor is an AAP and completes the Annual ACH Audit requirement with presentation to the Audit Committee and Board.

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#1997436 - 02/20/15 10:31 PM Re: oversight of ACH compliance [Re: Trees]
ahkcompliance Offline
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Joined: Sep 2008
Posts: 2,466
Midwest
Operations Officer along with Compliance prepares the risk assessment. Annual audit is outsourced.

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#1997438 - 02/20/15 10:38 PM Re: oversight of ACH compliance [Re: Trees]
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Electronic banking mgr was AAP certified and worked with Risk Manager (me) to stay current, update risk assessments, etc.
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#1997449 - 02/21/15 01:30 AM Re: oversight of ACH compliance [Re: Trees]
BetsyS Offline
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Joined: Jun 2009
Posts: 468
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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#1997833 - 02/24/15 05:21 PM Re: oversight of ACH compliance [Re: Trees]
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Thanks, everyone. Looks like this doesn't fall under the ISO's hat.
Makes sense for a combo oversight for us: Ops Mgr. and Compliance.

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#1998078 - 02/25/15 02:24 PM Re: oversight of ACH compliance [Re: Trees]
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,358
Somewhere
I'm in charge of both Operations and Compliance and one of my staff members in Ops is responsible for ACH.

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