Skip to content

The Compliance Makeover: A Mid-Sized Bank’s Journey to Audit Readiness


The Problem
 

A mid-sized regional bank in the Midwest was increasingly concerned about its ability to meet regulatory expectations around ACH oversight.  While transaction volume has steadily grown over the past five years, the bank’s risk management processes have remained largely manual and fragmented. 

The Treasury Services team was stuck in a cycle of spreadsheet audits, chasing down information across departments, trying to match data against legacy and core systems, and reacting to potential issues after the fact. Their biggest worry? Not being able to confidently demonstrate control and transparency during internal reviews for their board, potential audit findings, and inability to grow their ACH program.  

Key Challenges They Faced:  

  • No centralized view. ACH data lived in multiple systems, including the core banking platform, their mobile banking platform, the Fed Reporter, and multiple manual Excel spreadsheets. 
  • No originator risk score. Risk scoring was inconsistent and based on subjective judgment. 
  • No return rate tracking. Return rate violations were difficult to catch, and no ability to view trends. 
  • Manual audit processes. Audit logs were incomplete or hard to trace. The team often spent the majority of their time updating Excel sheets.
  • Manual high-risk account tracking. Monitoring high-risk clients required constant manual effort. 

Despite having a strong and growing team, they lacked the tools and visibility to scale their compliance operations as volume and regulatory expectations increased. 

The Solution 

To close these gaps, the bank deployed Affirmative’s Risk Manager, a purpose-built platform designed to give banks and credit unions full control over their ACH and payments data and risk reporting. 

This wasn’t just a technology upgrade; it was a strategic compliance transformation. Affirmative’s team partnered closely with the bank’s compliance and operations leads to map out their pain points and customize a rollout plan that delivered immediate relief. 

How Risk Manager™ solved key pain points:

Problem Solution
ACH data was spread across systems and required hours of consolidation.  Risk Manager created a unified, centralized view of all transactions, originators, and risk factors, eliminating the need for spreadsheet-based tracking.
Return rate thresholds weren’t clearly monitored or enforced. Return rate monitoring dashboards are aligned with NACHA rules, flagging violators and offering built-in visual evidence for audits and reporting.
Not all clients posed equal risk, yet there was no structured way to prioritize oversight and no reliable detection method. Affirmative’s Originator Score dynamically scores originators based on behavior, volume, and history. Automated thresholds and velocity checks triggered alerts for unusual activity.

The Result 

In just a few months, the bank transitioned from reactive, labor-intensive oversight to a streamlined, audit-ready posture. 

Key outcomes included: 

  • Audit prep time reduced by more than 50%.
  • ACH risk visibility improved across all departments.
  • Return rate compliance is achieved and maintained with ease.
  • The bank passed its most recent audit with zero findings related to ACH oversight.
     
“Our team now walks into audits with confidence instead of anxiety. Affirmative gave us clarity, control, and peace of mind.” 
– VP, Risk & Compliance
(Client anonymized per request) 

 

The transformation wasn’t just about meeting expectations, it was about exceeding them. With Affirmative, the bank now views compliance not as a burden, but as a competitive advantage.

 

Related Articles