Skip to content

Documentation: Bigger Than Lending

Compliance managers have long worked on lenders to improve documentation in loan files. We need the documentation to establish key pieces of information such as the date the application was actually taken and how the decision was made. Getting lenders to enter complete and consistent documentation has always been a compliance program issue.

With BSA examinations, and the current approach to policy, procedures and corporate management of compliance, the checklist approach to examinations is on the back shelf and the documentation approach is in.

When asked to evaluate what management and the board knew and when they knew it, examiners look for documentation - evidence that compliance program issues were reported and evidence that management and the board responded appropriately. The result is that the entire compliance program, from policies and procedures through training, monitoring, and auditing, must be documented with sufficient detail to satisfy examiners that the appropriate work is being done. So keep up those 3-ring binders!

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 12, 10/05

First published on 10/01/2005

Filed under: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics