VERSION 2.0 | FOUR PARTICIPANT TYPES | INSTANT DIGITAL DOWNLOAD
FedNow® Service Compliance Audits
Internal audit programs that test what your institution actually did, not what could go wrong. Four editions matched to how you participate, every requirement cited line-by-line to Operating Circular 8 (effective April 1, 2026) and the FedNow Service Operating Procedures v3.6.
Find Your EditionAn audit is not a risk assessment
They answer different questions, and examiners increasingly expect to see both. Here is the distinction in plain terms.
RISK ASSESSMENT
What could go wrong, and how exposed are we?
Prospective and scored. Likelihood multiplied by Impact produces an inherent risk score, then control effectiveness produces a residual score. Output is a risk register, a domain heat map and a risk appetite statement.
Audience: risk committee, senior management, board.
Performed by: risk or compliance.
COMPLIANCE AUDIT
Did we actually do what is required?
Retrospective and evidence based. Each requirement is tested against what the institution can produce for a defined audit period, and receives a binary result. Output is workpapers, findings with severity ratings, a report and a remediation plan.
Audience: board or supervisory committee, examiners.
Performed by: internal audit.
Choose the edition that matches how you participate
Scope drives everything. A receive-only institution should not be working through origination requirements, and a Correspondent carries obligations no participant edition covers. Pick the one that describes your institution.
RECEIVE ONLY
94 audit items | 12 sections | 38 rated High risk
For institutions that receive instant payments but do not originate them. The most common entry point for community banks and credit unions.
Covers: Authorized Connection Profile and sign-on status, response to Requests for Confirmation, immediate funds availability, Accept Without Posting, message signing keys, reconcilement, BSA/AML and fraud reporting.
SEND & RECEIVE
110 audit items | 14 sections | 50 rated High risk
For institutions that both originate and receive instant payments, without using the Request for Payment capability.
Adds: payment order format and eligibility, transaction limits, duplicate payment controls, customer authorization under Regulation E and Article 4A, per-customer exposure limits, origination fraud controls.
SEND & RECEIVE WITH RfP
123 audit items | 15 sections | 58 rated High risk
For institutions using the Request for Payment capability. Version 3.6 expanded these obligations substantially, and eight of the thirteen RfP items are rated High.
Adds a dedicated RfP section: the legitimate purpose tests for business and individual customers, UDAAP exposure, mandatory customer-level volume monitoring, investigation procedures requiring customer inquiry, and the warranty breach return process with its 95 calendar day deadline.
CORRESPONDENT
70 audit items | 11 sections | 38 rated High risk
For institutions that maintain a Master Account and settle FedNow activity for one or more Respondents. A different role, not a bigger version of the participant editions.
Covers: Settlement Account governance, Net Send Limit administration, Respondent onboarding and ongoing oversight, continuous intraday liquidity, and Correspondent-level reconcilement. Over half the program is rated High.
Every edition is a complete three-piece set
Workpapers to run the audit, a report template to issue it, and a guide that teaches an auditor who has never tested an instant payment program.
Audit Workpapers
Excel workbook. One tab per audit section, with the requirement, its citation, the risk level and the audit procedure already written. You complete the blue columns.
- Dropdowns for result, status, finding and severity
- Summary dashboard with findings tracker
- Rows sized to content so nothing is hidden
- No password protection: edit and extend freely
Sample Audit Report
Word document. A working template with illustrative findings you replace with your own results.
- Executive summary and results at a glance
- Scope, methodology and limitations
- Findings using condition, criteria, effect and recommendation
- Remediation summary and attestation blocks
User Guide
Word document. The companion that makes the workpapers usable by someone new to FedNow.
- A Payments Professor commentary on every single audit item
- Field-by-field explanation of every workbook tab
- Risk-based scoping for a constrained engagement
- Common examiner questions and how to answer them
Built on the rules in force today
Version 2.0 is written against Operating Circular 8 effective April 1, 2026 and the FedNow Service Operating Procedures v3.6 dated April 2026. Both superseded earlier versions, and the changes are reflected item by item.
Every item carries its citation
Each requirement names the provision it comes from, so a reviewer or examiner can follow your work back to the source. No item asserts an obligation without pointing to where it lives.
Two risk columns, not one
A pre-assigned Requirement Risk Level tells you where to concentrate testing effort. Exception Severity is yours to assign to findings. A High-risk requirement can produce a Low-severity finding, and the guide explains why that matters.
Written for a real engagement
Includes the areas institutions most often cannot evidence: certification test records, Service Level Expectations, message signing key rotation, and contacts that were set at implementation and never revisited.
Questions we get asked
We already have your Risk Assessment. Do we need the audit as well?
Which edition do we need?
Who is qualified to use this?
Can we edit the workbook?
What happens when the Reserve Banks amend the rules?
How long does an audit take?
Start with the edition that matches your profile
Each edition delivers instantly as three files: the workpapers, the sample report and the user guide. Licensed for use by your institution.
Compare the Four Editions