 |
|
| Client Testimonial "We initially engaged AuditOne to perform compliance audits. As a result of the excellent work in compliance and BSA, we have expanded the audit scope to other banking areas and we are highly satisfied with AuditOne's depth of knowledge. We are glad we made the change to AuditOne!" Andrea Worth
|
|
|||
| Compliance and BSA Despite the dramatic impact of credit and interest rate risk to earnings and the balance sheet, compliance risk continues to be an important subject for bank examiners. There are some regulations subjected to particularly high scrutiny such as Consumer Lending (Regulation Z), the Flood Protection Act, or the Community Reinvestment Act (CRA). In depth compliance audits are essential toward minimizing the number of compliance examination exceptions. The following list includes most of the compliance activities for you to be concerned with. • Compliance Program Management, Policies and Training • Regulation B - Equal Credit Opportunity Act • Regulation C - Home Mortgage Disclosure Act • Regulation D - Excessive Withdrawals • Regulation E - Electronic Funds Transfer Act • Regulation F - Limitations on Interbank Liabilities • Regulation GG - Prohibition on Funding of Unlawful Internet Gambling • Regulation H - Bank Protection Act • Regulation O - Insider Lending • Regulation P - Privacy of Consumer Financial Information • Regulation U - Loans Secured by Margin Stock • Regulation Z - Truth in Lending • Regulation AA - Credit Practices • Regulation BB - Community Reinvestment Act • Regulation CC - Expedited Funds Availability Act • Regulation DD - Truth in Savings • Fair Credit Reporting Act (Including FACT Act - Identity Theft Program) • Fair Housing Act • Flood Disaster Protection Act • Real Estate Settlement Procedures Act • Right to Financial Privacy Act • State specific financial codes Anti-Money Laundering and the Bank Secrecy Act (BSA) are separately covered in the scope of Safety and Soundness examinations and are also best covered in a separate audit. The risk profile for BSA is high for most banks and has earned itself a separate examination manual from the regulators, last released as an interagency reference guide at 405 pages by the Federal Financial Institutions Examination Council (FFIEC) in July 1997. The manual explicitly requires periodic independent testing and even describes the required scope of those independent tests. AuditOne has developed a proprietary approach to BSA audits based on the requirements of the FFIEC manual. We carefully adjust the scale of each audit depending on the money laundering risk profile of the institution being audited. Minimum required elements of an independent testing program cover the following elements. • Prior Audit and Examination Reports • Money Laundering Risk Assessment • Customer Identification Program • Customer Due Diligence • Suspicious Activity Monitoring and Reporting • Adequacy of Staff/Board Training • Currency Transaction Reporting • USA Patriot Act (Information Sharing) • Office of Foreign Asset Control • BSA Recordkeeping and Reporting Requirements • Assessment of BSA/AML Program • Other High Risk Activities |
||||
| (c) 2010 AuditOne, LLC. | Southern California Office 562.802.3581 | Northern California Office 408.980.8099 | info@audit-one.com | ||||