IT Examiner School

Examination – Access Wire & ACH Activities

Step 4 - Review written agreements:

• Place responsibility on customer for ensuring accurate and authorized transactions. • Explain authorized procedures for presenting instructions. • Include signature authority for persons authorized to provide instructions or files • Explain how or when, or if, the bank must verify transaction instructions before origination • Should address NACHA rules

Examination – Access Wire & ACH Activities

Step 5 Assess credit evaluation and approval processes for wire and ACH activities:

• Determine whether management prohibits sending funds until they are fully collected • If overdrafts are allowed, assess the adequacy of review/approval procedures and monitoring of customer’s overdraft and individual credit limit positions. • Determine if ACH limits are established, periodically reviewed, and enforced.