Compliance and Audit Flashcards
6 cards from real AAP practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 6 Compliance and Audit flashcards as text
Under NACHA rules, an ODFI's annual risk assessment must include:
Answer: Evaluating the ACH risk of each Originator and Third-Party Sender relationship
NACHA requires ODFIs to perform annual risk assessments that evaluate the ACH-related risks posed by each Originator and Third-Party Sender relationship.
NACHA's enforcement mechanisms for rules violations include:
Answer: Fines, suspension, or termination of ACH network participation
NACHA enforces its rules through a risk management framework that includes financial fines, suspension from the ACH network, and termination of participation rights.
The maximum NACHA fine for a willful rules violation is:
Answer: Up to $500,000 per incident
NACHA can impose fines up to $500,000 per incident for willful violations of the Operating Rules, with lesser amounts for less severe violations.
How frequently must ODFIs complete an ACH audit as required by NACHA?
Answer: Annually (at least once per calendar year)
NACHA Operating Rules require ODFIs to complete an ACH audit at least once per calendar year to assess compliance with the rules.
NACHA Operating Rules require ODFIs to monitor their Originators primarily for which key compliance metric?
Answer: Return rates—specifically the unauthorized debit return rate and the overall debit return rate
ODFIs must monitor Originator return rates, because excessive overall or unauthorized return rates indicate compliance problems that require ODFI intervention.
The overall debit return rate threshold that triggers NACHA review of an Originator is:
Answer: 15% of debit entries originated
An overall debit return rate exceeding 15% triggers NACHA review of the Originator's practices, as this indicates systemic problems with the origination.