Authorised Push Payment Regulatory Audits as a Service (APP RAaaS) External Auditor Brief
External Auditor Process:
​​​​1) Arrange the external interview call with the audit client and send relevant invites
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2) Review the CRM file on vTiger including website, social media, glass door reviews, trust pilot reviews, FCA register, Co House, annual financial reports and people and governance using LinkedIn​
3) Review the submitted app insurance application form in Sharepoint and associated attachments (if applicable - please make note on audit paper if not)​
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4) Review the submitted policies and documents in Sharepoint and highlight any missing documents and policies on the policy and document checklist (also in client folder in Sharepoint)​
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5) Review the heatmap for APP controls
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6) Review how the app fraud compared with the PSR latest app fraud report
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7) Review the scores and submitted comments from the APP participants on the Deep Fathom pinpoint system ​
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8) Compile a list of questions (example format) for the audit lead and submit to audit lead prior to call​
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9) Conduct the interview with the client audit lead (INSERT NAME AND DETAILS)​
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10) Complete the RAaaS external audit document and policy review adding comments where necessary (INSERT EA RVISTA LINK)​
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11) Complete the RAaaS external audit report adding comments where necessary (INSERT EA RVISTA LINK)​
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12) Complete written external auditor report to include:
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Any mandatory requirements before APP insurance can be granted
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Points that require investigation and clarification (especially intended improvements and/or project plan to improve APP)
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Suggested follow up items to be checked within (1 month, 3 months, 6 months)
13) Submit written external auditor report to Deep Fathom ​
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14) Independent QA review of final report (reviewed by a Green Swan Compliance oversight partner) ​
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15) Confirm approval to GSC team who will password protect the final report and issue to Elmore and client
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Useful links:
Maturity index key and heatmap examples
RAaaS external audit statements and responses
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