thomasmmc

Access to the FTP servers are IP restricted and everything is encrypted in transit and at rest on the server via PGP. In my organization the transfers where via FTPS not SFTP, big distinction, the FTPS implementations can be not as secure by default as SFTP. But yes, once it's on the ACH processors servers it's their responsibility and not your compliance issue. They will pass an audit, but from a security point of view, they could do it better in a few areas.

I used to work for an ACH organization in security, as the guy who set up the credentials, submitted the firewall changes, configured the FTP server, created the PGP keys, troubleshoot connectivity, you name it, all this. I know too much about the subject and I would say "its been 5 years I'm sure they have made it better" but after spending those years there, I know that statement is false.

To say it's secure is a stretch, so say it's completely unsecure is also inaccurate. There were multiple improvements I recommended to the service, but I think I only got 1 or 2 approved. Lets just say this, the front door is secure, but the once you're inside, its not so great. It's not incompetency, its just we (the security guys) are always fighting an uphill battle against change.

Also, I could tell you worst stories about other services all the banks use that would make anyone cringe worst than this, some simple cross bank privilege escalation, oh yeah and the developers said thats not really going to happen... I resigned within a month of that.