ACH Electronic Payments Audit Program - Banking
Objective 1: Determine the quality of risk management in support for ACH processing activities.
1. Review policies and procedures in place to monitor originating customer balances for credit payments (e.g., payroll) to ensure payments are made against collected funds or established credit limits. Also determine that payments in excess of established credit limits are properly authorized.
2. Determine if the institution treats deposits resulting from ACH transmitted debits on other accounts as uncollected funds until there is reasonable assurance the debits have been paid by the institution on which they were drawn. Also, determine if management monitors drawings against uncollected funds to ensure they are within established guidelines.
3. Determine if management monitors originating customers for unreasonable numbers of unauthorized ACH debits. If high, this could expose the institution to greater loss.
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