I'm looking for the date when BSA was changed to include independent testing of the program. Does anyone have any idea when this was?

Each of the Federal banking agencies issued regulations that required banks to develop a written BSA program. I looked up section 563.177 of the OTS regulations on the Electronic Code of Federal Regulations. Here is a link to it. http://ecfr.gpoaccess.gov/cgi/t/text/tex...0.1.1.32.6.31.6

At the end of the section, there is a reference to the November 30, 1989 issue of the Federal Register (54 FR 49552). If you could track that issue down, it might indicate when the requirement was effective.

Thank-you!!