When do I need to do a Risk Assessment? Have your policies and procedures changed with COVID-19?

by Mary Gilmeister, President, Macha

As technology and payments products evolve, so do fraud schemes, operational challenges, and regulatory requirements. Because of this ever-changing payment landscape, it is critical that financial institutions understand their risks and build a management program to control them.

According to the FFIEC, you should complete a Risk Assessment when:

• There are changes in technology;
  • Software
  • Processors
  • New services
• There are changes in your operating environment;
• There are changes in the number or types of originators;
• There are changes in the products that you offer;
• There are changes in returns or charge-offs; and
• There are changes in personnel.

What are the findings?

• Lack of strategic planning and risk monitoring;
• Audits not keeping pace;
• Outdated agreements;
• Regulation E inconsistencies; and
• Other issues.

Need Help?  Payment Advisory Resource and Macha have the following publications available for purchase:

• 2020 ACH Audit Guide for Financial Institutions
• 2020 Third-Party Sender ACH Audit Guide
• ACH Risk Assessment Guide
• ACH Policies and Procedures Manual

PAR conducts more than 150 audits per year, so don't hesitate to call us at (800) 453-1843 and make an appointment!