How to Conduct an ACH Risk Assessment and Develop an Effective ACH Risk Management Program


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Financial Institutions, Third Party Service Providers and Third-Party Senders who process ACH transactions can encounter a variety of risks such as credit, fraud and operational. According to the NACHA Operating Rules, financial institutions are required to assess and manage all ACH risks, particularly when the institutions engage in riskier ACH activities. The risk of fraud can be mitigated through proper due diligence for all originating customers and strict adherence to ACH and credit policies.

ODFI's and RDFI's are exposed to a variety of risks when originating, receiving, or processing ACH transactions, or outsourcing these activities to a third party. Financial Institutions should use guidance provided by FinCEN, the FFIEC and the OCC (in addition to the Rules developed by NACHA) to develop an ACH Risk Management program that reflects the nature and complexity of their activities.

Why Should You Attend:

This workshop will include a hands-on activity where participants can "assess the risk" of fictitious companies and third parties to help identify the importance of due diligence, setting exposure limits and adhering to the financial institutions ACH Policies on Origination and Receipt of ACH Entries. Exposure limits should be appropriate for the risks of each customer and identifying potential companies who may require the use of pre-funding arrangements or reserves (which can be effective in helping to control losses).

This workshop will identify the guidance provided and provide resources for effectively managing ACH Risk in the future. In this session, we will outline the key components of an effective ACH risk management program while participating in developing that program in a fictitious scenario.

The workshop will provide the details on the NACHA Operating Rules for conducting an ACH Risk Assessment and developing an effective Risk Management Program for the participants in the Network who are required to perform this task. In addition, details on guidance from FinCEN, the FFIEC and the OCC will be discussed. ACH Policies and the importance of them, reporting to the Board regarding your ACH program, and registration requirements (according to NACHA) for the ODFI will be included. A "must-attend" event!

Areas Covered in the Seminar:

  • How the ACH Network functions
  • NACHA Operating Rules on conducting an ACH Risk Assessment
  • Developing an effective ACH Risk Management Program
  • The different types of Risk and ways to mitigate
  • What’s needed for a successful ACH Risk Management Program
  • The importance of monitoring the entire ACH program on a consistent basis
  • The importance of Reporting details relating to the ACH Program to the Board
  • Registration requirements with NACHA

Who will Benefit:

Any payments professional working in the ACH Network will benefit from this course; these individuals could include operations, compliance, AR/AP, payroll, risk management, audit, legal counsel, management, risk officers, and AAP’s.

Field of Study:

  • Auditing: 6 CPE Credits
  • Management Advisory Services: 6.4 CPE Credits
  • Specialized Knowledge and Applications: 2 CPE Credits
  • Total CPE credits earned in this workshop: 14.4 CPE Credits

DAY 01(8:30 AM - 4:00 PM)

8:30 AM – Registration Begins

9:00 AM – Workshop Begins

9:00 – 10:30 AM

Overview on “How the ACH Network functions” and outline the NACHA Operating Rules on conducting an ACH Risk Assessment and developing an effective ACH Risk Management Program.

10:30 – 10:45 AM – BREAK

10:45 – 12 Noon

Define the different types of Risk and ways to mitigate. ACH Risk affects the ODFI and RDFI, Third-Party Service Providers and Third-Party Senders. Leads into a “hands-on” process of doing a Step-by-Step process of Assessing ACH Risk with Originating Companies and/or Third-Party Senders (TPS) using fictitious companies and one TPS to enhance the learning (includes the process of due diligence and setting exposure limits) from the ODFI perspective. Assessing the ACH Risk on the receive side of ACH transactions and the processing of those transactions will be part of this “hands-on” activity.

12 Noon – 1:00 PM – LUNCH

1:00 – 2:45 PM

Continuation of ACH Risk Assessment “hands-on” Activity. Around 2:30, move into the development of a Risk Management Program by introducing the key components within such a program, outlining details from guidance issued by FinCEN, FFIEC and the OCC.

2:45 – 3:00 PM– BREAK

3:00 – 4:30 PM

Continuation of discussion on what’s needed for a successful ACH Risk Management Program, outlining guidance from FinCEN, the FFIEC and the OCC (plus NACHA). Resources for workshop participants will be shared to aid in future ACH Risk Management programs.

DAY 02(9:00 AM - 12:30 PM)

9:00 – Workshop Resumes

9:00 – 10:30 AM

Recap from previous day (outlining all discussions and progress during hands-on activity). Continuing on with hands-on activity to include the development of an ACH Risk Management program for a “fictitious scenario” utilizing the companies/TPS from previous day for the ODFI program, including the RDFI perspective when receiving and processing ACH transactions.

10:30 – 10:45 AM– BREAK

10:45 – 12:30 PM

Continuation and completion of an effective ACH Risk Management Program, completing checklists to ensure all key components are included. Discussion on the importance of monitoring the entire ACH program on a consistent basis, reporting details relating to the ACH Program to the Board, and registration requirements with NACHA.

Seminar (Price/Register)
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