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Are Banks Required to have ACH Risk Assessment?

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Question: 
Does a bank 'have' to have an ACH Risk Assessment? Nacha Appendix Eight lists areas that should be audited, and suggests other areas internal audit should look at, including the ACH Risk Assessment; but doesn't clearly state whether or not one is required to have.
Answer: 

I suggest you review NACHA Operating Rules Subsection 1.2.4 (Risk Assessments) and Subsection 2.2.2 (ODFI Risk Management). In the Operating Guidelines, see the discussion of Risk Assessments in Section I Chapter 4 (page OG 21), the one on Risk Management of Internet/Mobile-Initiated Entries beginning on page OG 213, and the discussion of Risk Management for ODFIs on pages OG32 - OG34.

All references are to the 2011 edition of NACHA Operating Rules & Guidelines.

First published on BankersOnline.com 11/14/11

First published on 11/14/2011

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