Deposit Compliance audit may be something that is done every 1-2 years depending on the Bank's risk profile. As part of the Compliance Management System, an institution may also utilize monitoring in between audits. Audit must be performed by internal staff or external vendors that is independent of the function being audited. Monitoring can be performed by whomever the Bank feels has sufficient subject matter expertise to review. Depending on the complexity of the Bank this maybe the compliance area, or the Compliance Officer may delegate monitoring responsibility to individual departments and manage the results. If a significant number of errors are identified, the frequency and size of the sample may need to be increased. Since the risk profile of every institution is different, the frequency of monitoring that you need will differ from every other institution.
Other possible monitoring suggestions:
Regulation E Error Resolution files
Regulation CC Hold notices
Regulation D Excessive Transaction Monitoring - verify that individuals working reports and sending letters are following procedures.
Regulation DD Truth in Savings Disclosures - Test after any upgrades or changes to the platform to ensure that disclosures have not been altered.
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