Examiners will use their professional judgment and the credit union's risk profile to determine whether or not to review EPS activity and the depth and detail of that review.
While ATMs, card programs, and mobile payments are also EPS types, reviews of these areas are determined as risk profiles change.
| Wire Transfers | ACH | IP/RDC |
|---|---|---|
Once an examiner has reviewed the framework surrounding a credit union’s EPS activity (the strategic plan, policy, procedures, people, processes, and systems), they should assess how well the framework is working and the control environment that governs EPS activity by reviewing various aspects of the program. The results of this analysis can help examiners make a determination about the credit union’s management and administration of its electronic payment systems practices.
In addition to the steps outlined in the review procedures, examiners should consult the EPS Risk Overview job aid and document their findings as appropriate. Examiners should pay particular attention to:
- Violations of law, regulations, and third-party agreements;
- Significant issues that warrant inclusion in the exam report; and
- Potential impact of the observations on the CAMELS and risk ratings.
Last updated October 14, 2021
