I just attended the NACHA Payments 2007 conference this week in Chicago and thought I would pass along some interesting information.

Last fall the OCC come out with Bulletin 2006-39 which is a guidance regarding risk management of ACH activities. It is pretty comprehensive.

Several speakers at the conference indicated that the FFIEC will probably be adopting this same guidance. So, for those of you who aren't OCC banks and want to see what is probably coming down the road with regard to ACH, take a look at 2006-39.

The regulators discovered the ACH system in 2006. The OCC issued offical guidance and the FFIEC created a new section in the BSA/AML Handbook focused solely on ACH activity. Even though the overall program was much more broad that just ACH, the recent Texas Bankers Association's Compliance School Alumni Update included a session on ACH risk.

It's clearly a growing issue for all banks.