We will be having our first compliance exam under the new SMAART program later this month. In the past compliance exams have pretty much been non-events, but I understand that this is to be no more. Has anyone experienced this new exam process, and do you have any tips for me?

Our exam was completed in May using the SMAART guidelines. At this point there isn't much you can do to prepare. However, I can tell you that they are looking for a system of controls wherein the bank is able to review, identify and resolve regulatory issues. Once the examiners arrive they basically review your work papers and verify the system is functioning properly. Compliance Management and accountability are also under the magnifying glass. I will say that the team conducting our exam were some of the most affable with which I have ever worked.

Before I forget, Bank Secrecy and Flood were two very HOT topics. I would make sure those two areas are in order prior to their arrival.

Good Luck. I hope your exam goes smoothly for you.

Thanks Ace; I hope I have a similar experience. Anyone else have any words of wisdom for me? I tried to resign as Compliance Officer this morning, but they won't let me

We were examined in April under combined compliance/safety & soundness. The focus is whether you, as compliance officer, along with management are managing risk. They focused on BSA and privacy/information security. CRA was done offsite. The asked how prepared/knowledgeable we were in regard to the new HMDA rules. They were also very interested in our training methods and records. All in all - the exam went well.

Thank you for your input. How big is your bank? We're just over $275 million, and have 7 branches. I'm responsible for credit administration as well as compliance, so I'm spread a little thin! We're not in a major metropolitan area though, and most of our business is consumer or very small business (mom & pop stuff). We just had CRA last year and got an Outstanding, so I don't think they will be doing that again.

$1.9B bank, examined under SMAART in Nov 2003. Basically, they really wanted to see compliance risk assessment, mgmt support and your workpapers. They also reviewed my ECOA/Fairlending review with much scrutiny. Speaking with an OTS examiner recently at a meeting, they will be focusing very hard on BSA/AML this year. PM me if you would like more details.

Just finished our OTS Combined exam in April. I agree with all the comments above. If you have a formal risk assessment and do a good job with BSA you should be fine.

Good luck!

Hi

Can you tell me to what extent the OTS reviewed workpapers (ie: did they review all of the FinCen 314a requests as well as the scanning of all files for an overall check on OFAC?

We are having a highly technical examiner from Boston come to our shop and I believe that he will examine more documentation than risk management. However, I was contacted by an OTS official reminding me that the S.M.A.A.R.T. program should be followed.

Thanks for any input you can provide on this topic.