oversight of ACH compliance

Posted By: Trees

oversight of ACH compliance - 02/20/15 09:51 PM

Who has this responsibility in your community bank? Compliance Department? C.O.O.? I.S.O.? This person keeps up on changes and prepares risk assessments, etc.
Posted By: kiemo

Re: oversight of ACH compliance - 02/20/15 10:02 PM

Electronic Banking Manager with insight from the Compliance Officer completes a comprehensive risk assessment. The Internal Auditor is an AAP and completes the Annual ACH Audit requirement with presentation to the Audit Committee and Board.
Posted By: ahkcompliance

Re: oversight of ACH compliance - 02/20/15 10:31 PM

Operations Officer along with Compliance prepares the risk assessment. Annual audit is outsourced.
Posted By: Kathleen O. Blanchard

Re: oversight of ACH compliance - 02/20/15 10:38 PM

Electronic banking mgr was AAP certified and worked with Risk Manager (me) to stay current, update risk assessments, etc.
Posted By: BetsyS

Re: oversight of ACH compliance - 02/21/15 01:30 AM

It's difficult to get seperation of duty in a small bank. I complete both the ACH audit and the risk assessment, with reports going to our Operations and Management committees and the Board. I'm not an AAP, but I have been with my small bank for about 100 years working within the ACH framework since about day one and have kept up with the rule changes. I have also been our Reg E Compliance Officer (I manage Bancard), and do a compliance review while I'm at it. The key for us is that I am not part of the daily ACH operations.
Posted By: Trees

Re: oversight of ACH compliance - 02/24/15 05:21 PM

Thanks, everyone. Looks like this doesn't fall under the ISO's hat.
Makes sense for a combo oversight for us: Ops Mgr. and Compliance.
Posted By: P*Q

Re: oversight of ACH compliance - 02/25/15 02:24 PM

I'm in charge of both Operations and Compliance and one of my staff members in Ops is responsible for ACH.