we have had ACH staff perform, internal audit perform, and regional payments association perform. RPA used this to make 68 findings, with "training" being the suggested fix for most of the 68 (yes, training by RPA, of course, at a fee). We then sent our internal audit staff to training, and they perform. I stopped having the ACH staff perform as I felt there was the "appearance" of a conflict.
Providing alternative truths since the invention of time