As a State chartered bank, is there a regulation that requires internal audit to perform a Trust audit on an annual basis? Our risk assessment dictates a 12-24 month frequency. 12 CFR 9.9 relates to frequency of audits for National banks.

There isn't a state savings bank requirement in Texas, but we do an annual audit for the Trust department anyway. The FDIC does an annual examination of Trust and Registered Transfer Agent powers, so if you have done an internal audit when they come, there is a good chance they will rely on the internal audit and spend less time with you. The Trust department wants it this way as well, since they have some confidence they will have a good exam if they have a good internal audit.

Like Don, I'm not sure about state law. But if you have an SEC Registered Transfer Agent, there is an SEC requirement for at least an annual audit of the RTA.

We are a National Bank and I see the OCC every two years for a full-blown asset management exam and during the off-years, typically an examiner site visit for a few days.

And be sure to include comprehensive BSA steps in your Trust audit.