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#2226470 - 11/27/19 08:52 PM ACH policy
Compliance Action Subscriber 1226 Offline
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Joined: Sep 2015
Posts: 128
My bank is only a receiver of ACH transactions, not an originator - do we still need an ACH policy

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eBanking / Technology
#2226493 - 11/28/19 05:46 PM Re: ACH policy [Re: Compliance Action Subscriber 1226]
rlcarey Offline
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Joined: Jul 2001
Posts: 73,892
Galveston, TX
FFIEC IT Handbook

Policy - maybe not - adequate procedures are expected in the FFIEC IT Examinations Guidelines.

"Financial institutions and third-party service providers should have processes in place to ensure their understanding of, and compliance with, these and future rule and product changes."

It has been a while, so I am not sure how this is addressed specifically in the annually required ACH audit for an RDFI institution only.
The opinions expressed here should not be construed to be those of my employer:

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