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#412488 - 08/23/05 06:14 PM BSA Audit Program
SLC Offline
100 Club
Joined: Feb 2001
Posts: 185
Texas
In two recent instances, I was told by an OCC and an FRB examiner that use of the BSA examination procedures as a guide for annual independent reviews is not sufficient. Has anyone else heard this from their regulators? Does anyone have suggestions of third party vendor audit programs that have been updated in light of the expanded exam procedures?

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#412489 - 08/23/05 08:38 PM Re: BSA Audit Program
Retired DQ Offline
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Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
SLC, I would solicit a second opinion on that from your regional FRB director. That just has to be B-S!
I would think that you could completely rely on FFIEC's manual. (Geez, like life isn't hard enough)
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Get your facts first, then you can distort them as you please. - Mark Twain

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#412490 - 08/23/05 08:38 PM Re: BSA Audit Program
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
SLC, I would solicit a second opinion on that from your regional FRB director. That just has to be B-S!
I would think that you could completely rely on FFIEC's manual. (Geez, like life isn't hard enough)
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

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#412491 - 08/24/05 12:30 PM Re: BSA Audit Program
E.E.G.B Offline
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E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
Apparently DQ really feels strongly about this.... I do agree though - if you can't use the FFIEC guidelines, how come they can, huh??????
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I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.

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#412492 - 08/24/05 12:53 PM Re: BSA Audit Program
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
EGB
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Get your facts first, then you can distort them as you please. - Mark Twain

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#412493 - 08/24/05 01:43 PM Re: BSA Audit Program
Anonymous
Unregistered

Just audited by OTS and they encouraged us to use this as a guide. If you know what they are concerned with you work on it.

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#412494 - 08/24/05 02:45 PM Re: BSA Audit Program
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I believe that I would ask the examiner to explain, in detail, what issues are you failing to address by following the guidance in the FFIEC manual. Approach the situation eagerly and press for assistance in designing an appropriate BSA audit scope. The FFIEC manual is very comprehensive, I can't imagine what he/she is looking for that is not addressed.
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