Once the registry is up and running, will your Internal Auditor handle the annual independent testing or will it be outsourced to an external auditor? Our Internal Auditor was wondering about any confidentiality issues involved with the results of the criminal background checks on MLOs. Normally all audits of HR are handled externally. Would you have 100% of the registrations audited or would you just test a representative sample?
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.