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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: 124
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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rlcarey
Joined: Jul 2001
Posts: 73,318
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.
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