I'm desperately looking for some help regarding the annual ACH self audit. We're a de novo (opened just about a year and a half), I'm getting to this extremely late and I'm getting conflicting information from some other de novo's that about whether we have to complete this self audit or not. I think we do. We're outsourced to Fiserv ITI and they actually process our files, but we do originate as far as business customers payroll files they upload through our online banking. Aren't we still required to complete the self audit? Even if we didn't originate, wouldn't we still have to complete it since we're an RDFI? Just because we're outsourced, that doesn't take the responsibility off us correct? Any thoughts would be greatly appreciated.
"The reason I talk to myself is because I'm the only one whose answers I accept."
- George Carlin