I have been asked to design an audit for our FACTA program. I am kind of in the dark on this. Does anyone have any insight for me? Thanks

http://www.occ.treas.gov/ftp/bulletin/2008-28a.pdf

and see the attached to this document:

http://www.federalreserve.gov/boarddocs/srletters/2008/SR0807.htm

P.S. This is just the FCRA - FACTA was merely an amendment to the FCRA and does not stand alone.

Thanks Randy. I hear this a lot, FACTA, but wonder what happened to the rest of the FCRA. Does it go unaudited?

Andy,

I agree. I'm not sure how this got started (FACTA being treated separately) and I see a lot of banks that have developed specific FACTA policies and procedures outside of the FCRA policies and procedures that they may have had in place. It would be like developing new separate RESPA procedures for the recent RESPA amendments.

I have people trying to sell me respa policies. Do we not have to have a seperate respa policy/procedures?

There is no regulatory requirement to have written FCRA or RESPA policies and procedures (outside of the Red Flag requirements), but how do you instruct personnel on how to comply with the requirements without them?

OTS was just here and they looked at FACTA and FCRA together.

That is because FACTA is FCRA......