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#408675 - 08/15/05 09:29 PM Risk assesment in policy?
Anonymous
Unregistered

Should the BSA/AML risk assessment be incorporated into the board approved BSA policy?

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BSA/AML/CIP/OFAC Forum
#408676 - 08/15/05 09:36 PM Re: Risk assesment in policy?
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
No. The assessment is the "self examination" that determines what policies and procedures are appropriate for your institution. It's the prelude to establishing an appropriate compliance program, it's not part of the program itself. In addition, the assessment is not a static document. It will have to be redone routinely, either due to marked changes or the simple passage of time.

Presenting the assessment to the board, discussing it and noting that review in the minutes is appropriate. How can the board exercise its theoretical oversight of the adequacy of the BSA compliance effort if it has not been apprised of the risks?

_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#408677 - 08/15/05 11:41 PM Re: Risk assesment in policy?
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Ours is an exhibit to the program.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#408678 - 08/16/05 12:39 AM Re: Risk assesment in policy?
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Ours is a separate document in line with Ken's comments.

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#408679 - 08/16/05 07:15 PM Re: Risk assesment in policy?
Anonymous
Unregistered

I provide it as well. Keep them informed.

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#408680 - 08/16/05 07:15 PM Re: Risk assesment in policy?
Anonymous
Unregistered

I provide it as well. Keep them informed.

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