I recently conducted our first BSA internal audit with the new CIP procedures. I used the FDIC's exam procedures that included a review of a bank's CIP Program, has something changed?
Through discussions on these boards I have been surprised to hear that the examiners are not conducting detailed reviews of documentation to ensure a bank's compliance with the requirements. It seems to merely be a cursory review to make sure that when asked, employees respond properly to questioning. This seems awfully lax for a new regulation.