ACH policy

Posted By: Compliance Action Subscriber 1226

ACH policy - 11/27/19 08:52 PM

My bank is only a receiver of ACH transactions, not an originator - do we still need an ACH policy
Posted By: rlcarey

Re: ACH policy - 11/28/19 05:46 PM

FFIEC IT Handbook

Policy - maybe not - adequate procedures are expected in the FFIEC IT Examinations Guidelines.

"Financial institutions and third-party service providers should have processes in place to ensure their understanding of, and compliance with, these and future rule and product changes."

It has been a while, so I am not sure how this is addressed specifically in the annually required ACH audit for an RDFI institution only.