Vendor Guru Q&A - Compliance

Latest Compliance - Examinations Topics

Audit Preparation Seems to Take Our Bank a Lot of Time. Is That Normal?

09/01/2014

How long should it take us to prepare for an audit?

Should Our Audit Preparation Process Be Paperless?

09/01/2014

Is it worth it to go "paperless" for audit / exam preparation?

Subpoena/Summon Reports for Former Customers

08/25/2014

Our recent examiner said we must work up a potential SAR report for summonses & subpoenas. Does this apply if the subpoena is on a former customer (currently closed)?

Sample Copy of Due Demand Clause for Reg O

04/02/2012

Do you have a sample copy of the due demand clause for Reg O? We have FDIC examinations and run a good bank, but they say we should have an executive officer sign the due demand clause.

Gross Income for Loan Applicants

10/18/2010

We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?

HOAs & the USA Patriot Act

03/31/2008

An issue has arisen at my bank concerning the need for a signatory on a homeowners association account to submit his social security number. My bank's BSA Officer believes that he must do so. I am not so sure. This individual has no personal accounts with our bank, but is listed as a signatory on two accounts dealing with homeowner's associations. The person in question refuses to give his social security number. How are HOAs classified for purposes of the USA Patriot Act? It's my understanding that the HOA is the owner of the account. I know that the signatory situation was in the proposed rules, but not the final ones. I would appreciate it if someone could provide me with some guidance.