AAP Compliance and Audit

Question 1

Under NACHA rules, an ODFI's annual risk assessment must include:

Accepted Answer

Evaluating the ACH risk of each Originator and Third-Party Sender relationship

Answer

Submitting a formal risk report to both NACHA and the Federal Reserve

Answer

Conducting individual audits of all consumer Receiver accounts

Answer

Filing a Suspicious Activity Report for each high-risk Originator

Question 2

NACHA's enforcement mechanisms for rules violations include:

Accepted Answer

Fines, suspension, or termination of ACH network participation

Answer

Criminal prosecution through NACHA's in-house legal authority

Answer

Automatic account freezing by the ACH Operator

Answer

Direct Federal Reserve intervention and sanction

Question 3

The maximum NACHA fine for a willful rules violation is:

Accepted Answer

Up to $500,000 per incident

Answer

$100 per individual entry in violation

Answer

$1,000 per batch transmitted in violation

Answer

$50,000 as a flat fee per audit finding

Question 4

How frequently must ODFIs complete an ACH audit as required by NACHA?

Accepted Answer

Annually (at least once per calendar year)

Answer

Quarterly (every three months)

Answer

Monthly (at least once per month)

Answer

Every two years at minimum

Question 5

NACHA Operating Rules require ODFIs to monitor their Originators primarily for which key compliance metric?

Accepted Answer

Return rates—specifically the unauthorized debit return rate and the overall debit return rate

Answer

Average transaction dollar amount relative to industry benchmarks

Answer

Daily entry count compared to the Originator's origination limit

Answer

Consumer complaint ratio reported to the CFPB

Question 6

The overall debit return rate threshold that triggers NACHA review of an Originator is:

Accepted Answer

15% of debit entries originated

Answer

0.5% of debit entries originated

Answer

3% of debit entries originated

Answer

25% of debit entries originated