Last year the NACHA membership approved a rule that changes the structure of the ACH audit requirement within the NACHA Operating Rules. The new rule does not change the requirement that a Rules compliance audit must be conducted annually, but rather consolidates the requirements for the annual Rules compliance audit into one section and removes redundant material. This change was effective January 1, 2019 to apply to audits that are required to be conducted by December 31, 2019.
This rule change removes the audit requirement checklist that is currently found in Appendix Eight and combines relevant provisions with the general audit obligation required under Article One, Subsection 1.2.2. Parties that currently rely exclusively on Appendix Eight as a checklist for conducting their audits should be aware of its limitations and should be prepared to audit on all relevant rules, even those not expressly listed within current Appendix Eight language.
The robust ACH Compliance Audit service provided by ePayAdvisors has always extended beyond the stated requirements of Appendix 8, so we are well prepared to assist you in this new environment. Feedback from our audit clients indicates that one of the most valuable findings in our enhanced audit is identifying Origination returns, including internal origination, and monitoring them individually by SEC. Our clients also appreciate specific findings related to individual SEC codes and their authorization requirements, and WEB Origination Audit requirements.
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