ACH Self Audit - De Novo Bank

Posted By: ItNeverEnds CRCM

ACH Self Audit - De Novo Bank - 11/28/07 11:26 PM

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.
Posted By: Ready to Retire

Re: ACH Self Audit - De Novo Bank - 11/29/07 01:49 PM

You are correct. Any bank that is an ODFI or a RDFI must complete the self-audit. You do have some responsbilities even though you outsource as far as being an ODFI and you have said that you are a RDFI. Look at Appednix 8 of the NACHA rules.