Test patterns from APRA for customer payments
APRA has quietly signalled to banks and other ADIs that it expects them to conduct their own testing of customer payment files on a regular basis. The prudential regulator has done this by adding commentary to the "Frequently Asked Questions" area of its website. Question 13.2 reads: "What are an ADI's on-going obligations in relation to testing? What will the testing schedule mentioned in paragraph 25 of APS 910 contain, and when will it be provided by APRA?" In laying out the answer, APRA makes the distinction between "ongoing regular testing" that an ADI must conduct internally and the testing that an ADI must conduct in accordance with a testing schedule specified by APRA. The regulator has reassured the industry that financial institutions being tested will be given reasonable notice, in writing, of the schedule to be followed. APRA said: "This initial payment file testing has now been completed. ADIs will be advised should any further payment file testing be required."Tim Dring, Oceania banking leader for Ernst & Young, said the addition of the question to the FAQs really confirmed that APRA was "well underway" with the development of its testing schedules. "The key thing here is, basically, the requirement has been reinforced that this information can be provided to the RBA within 48 hours of it being requested. That really tests the data collection systems, controls and processes to make sure they are robust," said Dring.