We are in the same situation and you are now required to complete your own financial statements (our external auditors used to do this and we have been preparing for the last couple of years). You also have to have an Audit Committee that is independent of mgmt. We talked about this a lot with our External Auditors and mgmt can still stay on and attend meetings, however you should have an Executive session that is completely without mgmt and soley outside directors.
The FDIC has amended Part 363 of its regulations, which sets forth annual independent audit and reporting requirements for insured institutions with $500 million or more in total assets. The FDIC Board of Directors adopted these amendments in light of changes in the industry; certain sound audit, reporting, and audit committee practices incorporated in the Sarbanes-Oxley Act of 2002; and the FDICís experience in administering Part 363. The amendments also provide clearer and more complete guidance for compliance with Part 363
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell