Internal Control Questionnaires and Verification Procedures

Operations

1. Are all incoming and outgoing payment orders and message requests received in the wire transfer area, and are payment orders:

   1. Time stamped or sequentially numbered for control?

   2. Logged?

   3. Reviewed for signature authenticity?

   4. Reviewed for test verification, if applicable?

   5. Reviewed to determine whether personnel who initiate funds transfer requests have the authority to do so?

2. Are current lists of authorized signatures maintained in the wire transfer area?

3. Do those lists indicate the amount of funds which the individuals are authorized to release?

4. Are payment orders and message requests reviewed by someone other than the receipt clerk for:

   1. Propriety of the transactions?

   2. Future dates, especially for multiple transaction requests?

5. Are the receipt, data entry, and authentication functions in the wire transfer area adequately segregated?

6. Does a supervisor check all transactions prior to release of the payments?

7. Are all payment orders and message requests accounted for in an end-of-day proof to ensure that all requests have been processed?

8. Are all pre-numbered forms, including cancellations, accounted for in the end-of-day proof?

9. Does the wire transfer department prepare a daily reconcilement of funds sent and received over the system (CHIPS and FedWire) indicating the dollar amount and number of transactions?

10. Is the daily reconcilement of funds transfer and message request activity reviewed by supervisory personnel?

11. Are customer transfer and message requests that have been rejected by an in-house terminal carefully controlled and assigned a sequence number for accountability?

12. Are “as of” adjustments, open items, and reversals reviewed and approved by an officer?

13. Do records of funds transfer message requests contain:

    1. A sequence number?

    2. An amount, if funds are to be paid?

    3. The name of the customer making the request?

    4. A date?

    5. A test code authentication, if funds are to be paid?

    6. Paying instructions?

    7. Authorizing signatures for certain types and dollar amounts of transfers?

14. Does the flow of work proceed in a one-way direction to provide an adequate internal control environment?

15. Does someone not involved in the receipt, preparation, or transmittal of funds review all rejects and/or exceptions?

16. If the institution accepts transfer requests after the close of business or transfer requests with a future value date, are they properly controlled and processed?

17. Does the institution maintain adequate records as required by the Currency and Foreign Transactions Reporting Act of 1970 (also known as the Bank Secrecy Act)?

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