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#2270460 - 05/16/22 03:09 PM ACH Training and the Board
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 540
What type of ACH-related training do you provide to your Board of Directors and how often is this done?

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General Discussion
#2270462 - 05/16/22 03:18 PM Re: ACH Training and the Board TeamComply
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
None. Our Board training is high level training for items such as BSA, Risk Management, Lending patterns, etc.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2270464 - 05/16/22 03:31 PM Re: ACH Training and the Board ACBbank
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 540
We are using a third-party to complete our ACH audit this year, and this has been asked about? I wasn't aware of any actual requirement to train the BOD on ACH, but was wondering what, if anything, others do in this particular area. Our BOD training is typically and has historically been high-level as well. Thanks.

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#2270465 - 05/16/22 03:38 PM Re: ACH Training and the Board TeamComply
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
What practical benefit comes from training the Board on ACH? They will never initiate a transaction on behalf of the Bank. As part of our overall risk management training we provide the Board with KPIs/KRIs on our ACH activity, but we do this for all our products.

I am not aware of any regulation that requires the Board be trained on ACH activity, but this is hardly my area of expertise.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2270469 - 05/16/22 03:50 PM Re: ACH Training and the Board TeamComply
fmissle Offline
Diamond Poster
Joined: Jul 2007
Posts: 1,016
Pac NW
When we get the ACH Policy renewed annually we review the risk factors and processes in place for the Bank. This has, to now anyway, been sufficient for our auditors to see that the Board is aware of the program and the risks associated with it.

We also provide reporting quarterly on our Treasury Management volumes (# users, transaction $ and #, etc.).

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#2270478 - 05/16/22 05:30 PM Re: ACH Training and the Board TeamComply
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,844
Pulling people out of the ditc...
For purposes of ACH, on an annual basis we provide to the Board:

1. total number of originators and credit limits for them, for a risk perspective
2. total number of suspected Nacha Rules Violations filed against the Bank, and our response (if any)
3. Annual ACH policy renewal, even if there are no changes
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