I am set up on the Registry as an Administrator for our Bank. I am also the internal auditor. Am I able to do the SAFE Act Audit? I read somewhere that the audit must be independent. Does that mean a registered MLO couldn't do the audit? (i'm not, by the way)

HELP!! :S

Well, you definitely aren't independent.

hmmm. That's what I figured. Thanks!

I think you could do the audit if you passed off your duties as administrator. Many banks have given that function to their HR person or possibly their compliance person.

We have myself (compliance) and head of HR as administrators, with the audit done by IA. Unless you're a very small outfit, your setup wouldn't be considered sufficient. Easiest would probably be to pass off the admin responsibility to someone else, depending on how involved your second administrator is and if they would be able to handle it.

I am looking for some guidance on how to conduct the required annual test to insure we are in compliance with Safe Act independent testing. Anyone have any audit sheet they would like to share?

I used the OCC Handbook to set up a short spreadsheet. There is a SAFE Act worksheet at the end of the handbook that works nicely.

http://www.occ.treas.gov/publications/pu...-procedures.pdf