This bulletin supplements and should be used in conjunction with other occ and interagency issuances on thirdparty relationships and risk management listed in appendix b. The office of the comptroller of the currency occ is requesting comment on proposed guidelines, to be issued as an appendix to its safety and soundness standards regulations, establishing minimum standards for the design and implementation of a. Office of the comptroller of the currency, treasury. Currency occ financial statements for fiscal years 2007 and 2006. The workbook addresses risk criteria outlined in occ bulletin 2006 39, the ffiec retail payments systems it examination handbook and ffiec guidance to internet banking so that your company can identify strengths and weaknesses in your ach risk management program.
The occ bulletin 200639, automated clearinghouse activitiesrisk. Originating depository financial institutions odfis face unique challenges and potential risks in. Operating circular 4, occ circular 235 flashcards quizlet. In general, occ will enter all comments received into the. Content of the workbook includes risk criteria as defined in the occ bulletin 2006 39ach risk management guidance, the ffiec retail payment systems it examination handbook and the ffiec updated guidance to. Describes duties of users of consumer reports regarding identity theft. A background check on the principal business owners supplements the underwriting of the merchant client. Sep 01, 2006 28 see also, occ bulletin 2006 35, frequently asked questions. Office of the comptroller of the currency, bulletin 200639, ach activities sept. See instructions for items marked with an asterisk.
September 1, 2006 page 1 of 14 occ 200639 o occ bulletin comptroller of the currency administrator of national banks subject. The new guidance rescinds occ bulletin 200147 and occ advisory letter 20009. In this bulletin, occ defines high risk activities as engaging in ach. Gka, an independent certified public accounting firm, performed an audit of the financial statements of occ as of september. Start studying operating circular 4, occ circular 235. On october 30, 20, the office of the comptroller of the currency the occ issued updated guidance to national banks and federal savings associations on assessing and managing risks. September 1, 2006 page 4 of 14 risk management reports, including a comparison of actual performance to approved risk parameters. Office of the comptroller of the currency, treasury occ. The ffiecs bank secrecy actantimoney laundering examination manual, third party payment processors. June 30, 2007 previous editions will not be accepted after december 31, 2007 formerly form td f 9022. This bulletin outlines the key components of an effective ach risk management program. The workbook addresses risk criteria outlined in occ bulletin 200639, the ffiec retail payments systems it examination handbook and ffiec guidance to internet banking so that your company can identify strengths and weaknesses in your ach risk management program. This bulletin provides guidance from the office of the comptroller of the currency occ to national banks and federal savings associations collectively, banks on the application of consumer protection requirements and safe and sound banking practices to consumer debtsale arrangements with third parties e.
These principles are embodied in guidance we issued in 2006, n2 which we subsequently updated in 2008 n3 in connection with an occ enforcement action against wachovia bank. Requires agreements with service providers on disposal. Effective immediately, this bulletin rescinds occ bulletin 200023, bank purchases of life insuranceguidelines for national banks, dated july 20, 2000. Al 199708 allowance for loan and lease losses replaced occ bulletins 2007 and 200647. The spring 2015 report reflects bank financial data as of december 31, 2014. It is not uncommon for unscrupulous owners to use multiple business entities to avoid detection. Last year, the occ followed up with another bulletin occ 200812. Current list of occ alerts on unauthorized banking frbpr. This bulletin is intended to provide guidance to national. The occ publishes the report twice a year, drawing upon midyear and yearend data. March 15, 2006 page 1 of 1 occ 2006 12 o occ bulletin comptroller of the currency administrator of national banks subject. On october 4, 2006, the agencies issued the interagency guidance on nontraditional mortgage product risks. Chief executive officers and compliance officers of all national banks, department and division heads, and all examining personnel. Further, the occ is directing national banks that have not already done so, to conduct 2005 2004 2003.
V2 automated clearing house transactions overview objective. Sharing bank secrecy act resources occ bulletin 201836 october 2018. Occ, bulletin 2006 39, automated clearing house activities, sept. Guidance on managing risks of ach activity occ 200639 september 2006. Department of labor employment and training administration office of apprenticeship oa washington, d. Regulatory bodies such as fincen, ffiec, occ and others issue and update. Under a contract monitored by the office of inspector general, gka, p. Dec, 2006 the guidance attached to this bulletin continues to apply to federal savings associations. Thirdparty sender ach risk assessment workbook nacha. The final policy statement does not affect attachment 1 to the december 2006 interagency policy statement on. National banks may be exposed to a variety of risks when originating, receiving, or processing ach transactions, or outsourcing these activities to a third party. Advertisers and sponsors are not responsible for site content.
Office of the comptroller of the currency, september 1, 2006. The final policy statement does not affect attachment 1 to the december 2006 interagency policy statement on the allowance for loan and lease losses. Report to the congress on the use of the automated. Occ 200341 o occ bulletin comptroller of the currency administrator of national banks subject. Office of the comptroller of the currency docket no. For example, in 2006 the office of the comptroller of the currency occ released its risk management guidance for ach activities by national banks, occ bulletin 200639, in which it cautioned national banks acting as odfis to. You must include occ as the agency name and docket number occ 20110011 in your comment.
Occ bulletin 200812occ 200812 administrator of national. Occ bulletin 2006 39 ach risk management guidance originating depository financial institutions odfis face unique challenges and potential risks in thirdparty sender relationships. Content of the workbook includes risk criteria as defined in the occ bulletin 2006 39 ach risk management guidance, the ffiec retail payment systems it. Item detail ach risk assessment workbook downloadable. Statutes, regulatory guidance, supervisory memorandums, select legal opinions. Office of the comptroller of the currency, 250 e street, s. Chief executive officers, chief risk officers, and compliance officers of all national banks, federal branches and agencies, technology service providers, department and. Occ bulletin 2006, amendments to regulation cc and j. Al 199708 allowance for loan and lease losses replaced occ bulletins 2007 and 2006 47. Statutes, regulatory guidance, supervisory memorandums.
Automated clearing house transactions overview ffiec bsaaml examination manual 217 2272015. From the agencies march 2006 archive american banker. Government pension payments were introduced in 2006. For example, in 2006 the office of the comptroller of the currency occ released its risk management guidance for ach activities by national banks, occ bulletin 2006 39, in which it cautioned national banks acting as odfis to. March 15, 2006 page 1 of 1 occ 200612 o occ bulletin comptroller of the currency administrator of national banks subject. They may not be relied upon as authoritative interpretations. Occ bulletin 200639 ach risk management guidance originating depository financial institutions odfis face unique challenges and potential risks in thirdparty sender relationships. Sound business practices for evaluating customer risk nacha. A major factor in this growth was integras acquisition, in april 2007, of prairie, a state chartered bank in the chicago area with a. The ebanking booklet replaces the occ internet banking handbook and occ bulletin 9838, technology risk management.
That guidance includes guidelines for managing the risks associated with closedend residential mortgage products that allow borrowers to defer payment of principal or interest, including consumer protection issues. The guidance attached to this bulletin continues to apply to federal savings associations. This bulletin provides guidance for national banks and examiners on managing the risks of automated clearing house ach activity. Occ, bulletin 200639, automated clearing house activities, sept. Home about the occ news and issuances publications tools and forms topics home news and issuances bulletins 2011 news and issuances news releases bulletins 2011 2010 2009 purpose2008 2007 2006 foreclosure activities by national banks. Large institution cra examination procedures, published in occ bulletin 200617. Bankersonline is a free service made possible by the generous support of our advertisers and sponsors. This userfriendly workbook is designed to take thirdparty senders stepbystep through the ach risk assessment process. The occs semiannual risk perspective addresses key issues facing banks. Bulletin 2006 39 automated clearing house activities. The merchant processing booklet of the comptrollers handbook.
The office of the comptroller of the currency, the board of governors of the federal reserve system, the federal deposit insurance corporation, the office of thrift supervision, and the national credit union administration the agencies have jointly issued the attached interagency guidance on nontraditional mortgage product risks. Risk management principles, and occ advisory letter 20009, thirdparty risk. Occ 200624, interagency agreement on erisa referrals occ 20042, banksthrifts providing financial support to funds advised by the banking organization or its affiliates occ bulletin 200216, bank use of foreignbased thirdparty service providers occ bulletin 2005, examination procedures to. To mitigate risk, it is critical that odfis fully understand their responsibilities and inherent risks in third party relationships. Handbook and occ bulletin 9838, technology risk management. The office of the comptroller of the currency, the office of thrift supervision, the board of governors of the federal reserve system, the federal deposit insurance corporation, and the national credit union administration collectively, the agencies, have issued an interagency policy statement on the. For further guidance on issues associated with boli, contact christopher manthey, bank activities and structure at 202 8745300 or kurt wilhelm, treasury and market risk at 202 8745670. Audit the depth and breadth of a banks ach audit program will depend on the volume and complexity of its ach operations. Oct 30, 20 this bulletin rescinds occ bulletin 200147, thirdparty relationships. Occ updates guidance on thirdparty risk management november 12, 20. Content of the workbook includes risk criteria as defined in the occ bulletin 2006 39ach risk management guidance, the ffiec retail payment systems it. Act on the date when the registry begins accepting federal registrations, it will announce that date in advance and notify national banks and their residential mortgage loan originator employees that they will then have 180 days to comply. Odfi best practices to close the gap, an ach risk management white paper 2009.
Please help us keep bankersonline free to all banking professionals. Statutes, regulatory guidance, supervisory memorandums, select legal opinions information technology. Guidance on automated clearing house activities, occ bulletin 200639. Applies to fsas with the issuance of this bulletin. A major factor in this growth was integras acquisition, in april. Third party payment processors job aid this job aid is to be used by state institution examiners as a means to understand, identify, and assess the risks associated with institutions relationships with a common type of thirdparty service provider, thirdparty payment processors or senders, herein referred to as tppps or processors. Jul 16, 2014 these principles are embodied in guidance we issued in 2006, n2 which we subsequently updated in 2008 n3 in connection with an occ enforcement action against wachovia bank.
The challenge of diminished capacity, aarp public policy institute nov. Occ 200624, interagency agreement on erisa referrals occ 20042, banksthrifts providing financial support to funds advised by the banking organization or its affiliates occ bulletin 200216, bank use of foreignbased thirdparty service providers occ bulletin 2005, examination procedures to evaluate. Explore occ news releases and issuances on a wide variety of bankingrelated topics. Sr 097 fil612009 occ bulletin 200932 interagency guidance on concentrations in commercial real estate, 71 fed. On october 30, 20, the office of the comptroller of the currency the occ issued updated. Replaced occ bulletin 2001 20 occ 199839 compliance software. Office of thrift supervision ots, cra examination procedures for large retail savings associations, contained in the ots examination handbook. Assess the adequacy of the banks systems to manage the risks associated with. Risk involved in remote deposit capture bankers online. House financial services subcommittee on oversight and. Chief executive officers of national banks, federal branches and agencies, and technology service providers, department and division heads, and.
See also occ advisory letter 20023, guidance on unfair or deceptive acts or practices. This balance brings to mind direction from occ 200639, and why its. The occ has seen several cases in which a banks ach. Ebanking booklet this booklet reflects the occs views on the risks specific to ebanking and provides bankers and examiners with guidance on those risks and the risk management issues associated with the.