Does the regulation specifically require that an independant audit (i.e., internal auditor) be performed or, can the compliance officer conduct a Compliance Review to satify reg. provisions?

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Can someone move this to the correct forum?
Thank you

can the compliance officer conduct a Compliance Review to satify reg. provisions

As long as the CO is not involved in any way with the administration of the SAFE Act procedures then they should be able to do an independent audit.

I am the CO and have admin rights to the NMLS system. I don't not outsource the audit. It is a pretty easy audit for another employee to perform. I went through the regulation and created an audit sheet and usually will have another employee (someone not involved with the ACt or a MLO) and have them peform the audit. They look over policy/procedures to make sure everything is addressed, will make sure we post the unique identifier and also asks some non MLO loan officers questions to make sure they don't do any transactions they are not suppose to. The FDIC was satisfied with the process.

Would you share your audit sheet?

I would like to see your wudit sheet too if you don't mind sharing.

Is this other employee familiar with the regulation and the audit requirements?

Would you mind sharing your audit sheet with me? Our Compliance Officer would like help with this audit.