Annual ACH Rules Compliance Audit

Annual inspection template for reviewing ACH policies, return handling, risk management, and recordkeeping against Nacha Operating Rules audit requirements.

Audit Scope and Program Setup

• Audit period and ACH business lines in scope are documented
• ACH policies and procedures reviewed are the current approved versions
• Audit owner and remediation contact identified
• Prior audit findings and open corrective actions were reviewed
• Evidence package includes policy, procedures, reports, and exception logs

ACH Policy Governance and Training

• ACH policy includes defined roles, responsibilities, and approval authority
• Policy addresses origination, receipt, returns, reversals, and exception handling
• Employee training on ACH responsibilities is current and documented
• Training completion rate for assigned ACH staff
• Policy review cycle and next review date are documented

Return Item Handling and Exception Processing

• Return items are reviewed and processed within required timeframes
• Return reason codes are accurate and supported by documentation
• Reversals and corrections are authorized and documented
• Exception items are escalated according to procedure
• Sampled return item error rate

Risk Management and Controls

• Risk assessment for ACH origination and receipt is current
• Dual control or equivalent approval controls are in place for ACH file release
• Access to ACH systems is restricted to authorized personnel
• Monitoring for unusual activity, duplicate entries, or out-of-pattern transactions is documented
• Fraud response or incident escalation procedure is documented and tested

Records, Reporting, and Sign-Off

• Audit evidence is retained according to the record retention schedule
• Management review of audit results is documented
• Corrective actions include owner and target completion date
• Inspector signature
• Audit completion date