I'd also be interested in any keywords I could use to search for internet gambling (a recent auditor recommendation).
After looking up "vacuous," I agree with rlcarey's response. For decades I've bristled at examiner recommendations that purely indicated they could not find anything of substance. Now, auditors are apparently facing the same dilemma and responding in the same way. My two most recent favorites:
* The bank needs documentation for the percentage of revenues an exempt customer derives from ineligible activities. (There really is no "pat" way to do that and it would require deposit customers to provide information regarding income that some borrowers balk at providing. I'd rescind the exemption instead.)
* The bank should begin identifying beneficial owners of all entity customers. (The requirements should be added to it's CIP.) If the ABA spends 27 pages analyzing FinCEN's proposal as [censored] I don't see the wisdom of adopting it voluntarily. In addition, it falls under CDD, not CIP.
If a bank finds its auditor's recommendation vacuous it should first respond in writing to that effect and second, start looking for a new auditor.