I would recommend you include as a step in your audit to pull a list of customers and the fees they paid in the program during the last year. Then sort the list by the fees paid, if you are in shock when you look at the bottom, dont forget to consider UDAP. I used the best practices guidance and the commercial bank exam manual to help build a program. You should be able to take the 2005 and 2010 guidance and have a pretty solid start, just answer each bullet, and then consider the introductory statements in the guidance for your overall assessment.
Last edited by Justin Wesson; 03/07/11 11:52 PM.
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