I need some help - I thought that the OCC put out a memo or bulletin on how they view compliance with interagency guidance. Specifically - how they view noncompliance with interagency guidance. Audit is writing up noncompliance with an interagency guidance as a violation of law/regulation.

Regardless of who issued a guidance document, a guidance document is not law or regulation and should never be cited as such. Audit needs to re-think their approach. Can failure to follow regulatory guidance be a finding - sure. Cited as a violation of law or regulation - not on your life.

Thanks rlclarey - I totally agree but was hoping to have something in black and white from the regulatory agencies on how they view it and I thought they issued something in the past.