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#2048490 - 11/06/15 05:34 PM AML Model Validation
Sephiroth Offline
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Has anyone that has Fiserv's AML Manager been asked by an examiner for a model validation in accordance with the OCC Bulletin 2011-12, gotten said model validation? if so, can you recommend a company/accounting firm that does this kind of third party model validation?

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#2049092 - 11/10/15 08:04 PM Re: AML Model Validation Sephiroth
bhazzard Offline
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We are not OCC regulated, however, we do use AML Manager and did receive a recommendation to get it validated. We did use a 3rd party vendor to validate the program. Feel free to PM me and we can discuss further. I am not sure that we are supposed to really recommend or discuss specific vendors or service providers in the threads.

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#2049527 - 11/13/15 03:03 PM Re: AML Model Validation bhazzard
Rudy06 Offline
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We don't use AML manager but we did go through an AML model validation earlier this year. Crowe Horwath did it. 3 weeks with 4 auditors on site. Ran us about $80K.

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#2050744 - 11/20/15 06:55 PM Re: AML Model Validation Sephiroth
Notsobsa Offline
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bhazzard I sent you a PM for more information.

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#2053637 - 12/10/15 08:15 PM Re: AML Model Validation Sephiroth
Jennifer Offline
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Is Model Validation a requirement??

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#2053649 - 12/10/15 08:38 PM Re: AML Model Validation Sephiroth
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You are here
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#2053664 - 12/10/15 09:15 PM Re: AML Model Validation Sephiroth
ACBbank Online
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It's not required as long as the regulators don't find anything wrong with your system. I've heard of regulators requiring a model validation when they find issues during their BSA/AML reviews.
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#2053697 - 12/10/15 10:34 PM Re: AML Model Validation Sephiroth
rlcarey Online
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In my region, they are pushing more and more for some sort of model validation whether there are problems or not.
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#2053836 - 12/11/15 07:41 PM Re: AML Model Validation rlcarey
Cape Codder Offline
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^^This.
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#2053840 - 12/11/15 07:50 PM Re: AML Model Validation Sephiroth
osucpa Offline
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As an OCC bank, the examiners expect model validation from us on a periodic basis.

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#2054124 - 12/15/15 10:44 AM Re: AML Model Validation Sephiroth
luvflipflops Offline
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It is a requirement... ever since the first BSA/AML Exam Manual in 2005, one of the testing requirements within the Suspicious Activity Reporting section states that examiners/auditors should ensure the Bank has performed an independent validation (independently verified) if they utilize an automated AML system. So examiners are just now getting around to enforcing it.

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Last edited by Andy Z; 12/15/15 02:51 PM.
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#2054377 - 12/16/15 02:29 PM Re: AML Model Validation rlcarey
AnnRoy Offline
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Randy,

Are regulators requiring the model validation to be conducted annually or when deemed necessary (ex - core conversion or other significant event)?
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#2054487 - 12/16/15 06:39 PM Re: AML Model Validation Sephiroth
rlcarey Online
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Not necessarily annually, but you better have one and have it updated based on perceived risk.
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#2054699 - 12/17/15 03:51 PM Re: AML Model Validation Rudy06
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Houston
What % is the validation cost compared to the annual cost of your AML software? Are we expected to spend as much validating the software as it costs each year? Using the phrase "periodically" I believe the examiners mean at least once between exams or when you add products.
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#2054710 - 12/17/15 04:22 PM Re: AML Model Validation Sephiroth
osucpa Offline
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We are expected to have model validation on a variety of programs. This would include AML software and any automated loan underwriting program being used. They do not expect us to validate annually but on a periodic basis (risk based approach).

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#2057898 - 01/11/16 09:05 PM Re: AML Model Validation Sephiroth
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Last edited by Andy Z; 01/11/16 10:00 PM.
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