IT Examiner School, Seaside, CA

General ACH risk

ACH transactions are usually considered one of the higher risk EFT transactions, especially for the ODFI.

• Credit Risk

• Liquidity Risk

• Operating Risk

• Third party payment processor risk

ACH Exceptions Often Noted at Examinations

• Risk tolerance for ACH activities not defined by the Board. • Insufficient Board reporting. • Lack of written policies and procedures. • Lack of compliance with enhanced authentication requirements. • No underwriting or annual review of customer exposure limits. • Lack of effective monitoring (anomaly detection, fraud, changes in volumes, etc.).