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Another BSA Enforcement by FRB
The FRB, together with the Ohio Division of Financial Institutions, has reached a written agreement with the Custar State Bank to resolve deficiencies in compliance with BSA and lending practices. The bank must rapidly implement a forensic audit of accounts for the prior two years, implement adequate controls to ensure compliance with BSA and appoint a qualified BSA officer.
The written agreement requires the bank to adopt acceptable loan policies and procedures including adequate underwriting standards, and to maintain adequate loan file documentation - including memoranda by loan officers. Finally, the bank must take steps to provide for orderly management succession by identifying personnel capable of assuming new duties.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 1, 2/04
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