Our Originator Compliance Review Service provides ODFIs an opportunity to have a more detailed or focused review of specific Originators and enhances the periodic review for those specific Originators with a more in-depth compliance focus. You may select to review high-risk Originators or even Originators in a particular industry.
In conjunction with an evaluation of the Originator policies, procedures, and processes, the review focuses on the Originator’s understanding and compliance with applicable sections of the Nacha Operating Rules. We include originator compliance with approved SEC codes, authorizations, retention requirements, and return rates in our review. As a part of our audit procedures, we include tests of documentary evidence supporting compliance with the ACH Rules and analyze Origination and Return files to identify anomalies that may need to be addressed.
At the conclusion of the engagement, we provide you with a comprehensive report of each Originator’s areas of non-compliance or compliance deficiencies that may need to be addressed with the Originator(s) in order to mitigate potential risk and liability.