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#754575 - 06/15/07 09:27 PM ACH Originator Audit
bearkat007 Offline
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Joined: Jun 2007
Posts: 3
My contracted information security guy has requested I do an ACH Originator Audit. He is requesting that I develop an audit procedure, where I would physically go and audit my originators. I do not have but a handfull.

Question is, does any one else do this?

If so, what and how are you doing this with. Would anyone be interested in shareing their checklist?

Thanks

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Audit
#754748 - 06/17/07 02:04 PM Re: ACH Originator Audit bearkat007
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
First, I would review my contracts with the ACH originators to see if you have even reserved the right to go in a perform such an audit. Most standard contracts that I have reviewed to not include that right.

Second, I would ask your IS guy what this request is based on. I have never heard of a bank going out and auditing their ACH originators. What exactly does he want you to audit??? There is no such requirement in the FFIEC IS Examination Manual.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#754799 - 06/18/07 01:12 PM Re: ACH Originator Audit rlcarey
bearkat007 Offline
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Joined: Jun 2007
Posts: 3
We are really bumping heads over this. I have come up with a list of a few questions for my originators. I will just call and make sure they are following the rules.

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#755661 - 06/19/07 01:30 PM Re: ACH Originator Audit bearkat007
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Of what value is that? You already have a contract with them that says they are going to follow all the rules. Do you think they are going to say on the phone to you that - awwww - we don't really get authorizations from any of our customers that we debit????

I would again recommend that you go back to the IS guy and ask him where in the regulations or other guidance is this recommendation coming form - if he can't answer that - then take his "recommendation" under advisement - and immediately move on to your next project.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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