ACH Audit - Better late than never?

I have recently joined the internal audit department of a bank holding company. The previous internal auditor started the 2009 ACH Audit in November, but didn't complete it. I have now been charged with getting it done. Obviously, the December 1 deadline has been missed. To complicate the situation, the ACH process was consolidated under the holding company from 5 invidual banks at the end of 2009.

I believe that the audit needs to be completed. However, I am unsure about "when" to test. Should I test transactions prior to December 1? I know that the consolidation resulted in several procedural changes and am afraid that it will be inefficient to test prior to the consolidation. Any thoughts?

That happened to me when I started in my role as Internal Audit Director in December 2006. When I realized the ACH audit had not been performed in 2006, to be efficient, we did two audits simultaneously in March 2007 - we tested transactions prior to December 1, 2006 and tested transactions in 2007 for the 2007 audit. So we were late for 2006 and early for 2007.

Just my opinion, I think it is better to be late than not in compliance at all.