AAP Compliance and Audit 3

Question 1

Excessive administrative return rates (R02, R03, R04) for an Originator may indicate:

Accepted Answer

Data quality problems or potential fraud in the Originator's account database

Answer

An automatic trigger for NACHA suspension of the Originator

Answer

A requirement to file a CTR with FinCEN for each returned entry

Answer

Loss of settlement rights at the ODFI level

Question 2

Under Regulation E, a financial institution's error resolution process must be completed within:

Accepted Answer

10 business days (or 45 calendar days if provisional credit is extended to the consumer)

Answer

2 business days in all cases

Answer

60 calendar days as the maximum allowed period

Answer

5 business days regardless of circumstances

Question 3

When must an ODFI suspend an Originator's ACH origination privileges?

Accepted Answer

When the ODFI determines the Originator has materially breached the origination agreement or NACHA rules

Answer

After any single returned entry regardless of return code

Answer

When the ODFI's aggregate return rate exceeds 1%

Answer

Only when NACHA formally orders the ODFI to do so

Question 4

Same-Day ACH rules require ODFIs to submit same-day entries to the ACH Operator by:

Accepted Answer

Specific same-day processing windows (e.g., 10:30 AM ET and 2:45 PM ET)

Answer

Midnight of the processing day regardless of time zone

Answer

Before 9:00 AM ET for guaranteed same-day settlement

Answer

Any time before 5:00 PM local bank time

Question 5

The administrative return rate threshold (R02, R03, R04) that triggers NACHA review of an Originator is:

Accepted Answer

3% of ACH debit entries originated

Answer

0.5% of ACH debit entries originated

Answer

15% of ACH debit entries originated

Answer

1% of ACH debit entries originated

Question 6

Under NACHA rules, a Third-Party Sender's compliance obligation includes:

Accepted Answer

Entering into a written agreement with the ODFI acknowledging its responsibilities under NACHA Operating Rules

Answer

Obtaining direct NACHA membership as a condition of operation

Answer

Annual CPA certification of its ACH transaction volumes

Answer

Registering directly with the Federal Reserve before transmitting entries