Does your bank's BSA program address the Report of Foreign Bank Financial Accounts? I would guess that 90% of the banks in the U.S. have no accounts of their own (they have signing authority for) in foreign countries, but in spite of that, even if it is non-applicable, should there be procedures spelled out in a bank's BSA Program ???

Somehow, I'm getting the impression that you just got criticized for this "failure." If I am correct, I would like to congratulate you on having an excellent Bank Secrecy Act Compliance program. In a portion of my home state this criticsm is the emblem that the FDIC attaches to every report on a bank where they could not find anything of substance.

Did they also suggest that you should file the form too, even though it clearly says you do not have to in the first paragraph?

Welcome to Trivial Pursuit! Would you like to go to the next level?

Does your lending policy specifically address underwriting standards on deep water vessels, even though you have never made any such loans and are 500 miles from the ocean?