DCU Bulletin B-16-14 Electronic Payment Systems Exams

The Division of Credit Union (Division) announced that it is enhancing its safety and soundness examinations to include Electronic Payment System (EPS) reviews. EPS exams will be performed by Division examiners beginning in 2017.

The Division will perform one or two pilot test payment system exams at credit unions in the fourth quarter of 2016 before implementing its new EPS examination program in the first quarter of 2017. In 2017, the Division will perform EPS exams on Washington state chartered credit unions with over $250 million in total assets.

EPS exams will usually last no longer than three days onsite and these exams will be performed during the regular safety and soundness examinations. A separate EPS rating will not be given, although the “Management” component rating of CAMELS could be adjusted up or down based on the EPS examination. Examination issues and examiner’s findings regarding electronic payment systems will be incorporated into the safety and soundness exam report.

Division EPS examiners will focus their reviews on the following:

  • EPS risk assessments;
  • EPS audits (both external and internal);
  • EPS policy and procedures; and
  • EPS limits and controls that are in place.

Additionally, examiners will focus on new EPS services and the credit unions’ internal controls, limits and processes in place to minimize and reduce risks.

Examiners will use the following existing AIRES questionnaires pertaining to electronic payment systems;

  • IC – ACH General,
  • IC – Payment Systems – FRB,
  • IC – Wire Transfers,
  • IC – ATM
  • Remote Deposit Capture Procedures,
  • IC – ACH RDFI,
  • IC – ACH ODFI (moderate risk), and
  • IC – ACH ODFI (high risk).

Credit unions should ensure that EPS risk assessments, policies, and procedures are current.  Credit unions can also review the AIRES questionnaires in preparation for questions from examiners.

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