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#205668 - 06/29/04 08:25 PM Frequency of trust audits
MackenzieS Offline
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MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
Can someone tell me what the audit frequency is for banks to conduct internal trust audits? I think it is either every 12 or 18 months, but I am having trouble finding it. Thanks!

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Audit
#205669 - 06/30/04 04:39 AM Re: Frequency of trust audits
Risk Officer Offline
100 Club
Joined: Apr 2001
Posts: 205
Dallas
The FDIC's Statement of Principles of Trust Department Management require an annual audit of trust department activities. I am not aware of similar specific requirements from the Fed or OCC (haven't really looked that hard, though). What I have seen from the other regulators is that audit should be (of course) appropriate for the size and complexity of the department...based on risk assessment, etc. Sorry I couldn't provide more.
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#205670 - 06/30/04 01:29 PM Re: Frequency of trust audits
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
Hmmm... I thought they were supposed to be conducted at least once each calendar year??!?!?!?! Now I am confused.
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#205671 - 06/30/04 02:08 PM Re: Frequency of trust audits
MackenzieS Offline
Diamond Poster
MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
Quote:

The FDIC's Statement of Principles of Trust Department Management require an annual audit of trust department activities. I am not aware of similar specific requirements from the Fed or OCC (haven't really looked that hard, though). What I have seen from the other regulators is that audit should be (of course) appropriate for the size and complexity of the department...based on risk assessment, etc. Sorry I couldn't provide more.




Thanks, I finally found it after digging and digging. It sounds like for a large bank they prefer an ongoing audit whereas a small institution may conduct an annual audit. I appreciate your help!

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#205672 - 06/30/04 03:34 PM Re: Frequency of trust audits
Anonymous
Unregistered

OCC Requirements-Reg 9.9 states-At least once during each calendar year, a national bank shall arrange for a suitable audit (by internal or external auditors) of all significant fiduciary activities, under the direction of its fiduciary audit committee, unless the bank adopts a continuous audit system in accordance with teh paragraph b of this section.

Federal Reserve - Industry Audit Guide - Fed recognizes continuous audit as well as one shot annual audit -Fed SR 83-17 states that exceptions to an annual audit should be documented

OTS - 12CFR 550.7 at least once during each calendar year an association's trust department shall be audited (either internally or externally)

The size of the trust department, complexity of business, degree of internal controls, organizational structure, and previously identified problems will affect the frequency and the level of testing.

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#205673 - 06/30/04 04:18 PM Re: Frequency of trust audits
Anonymous
Unregistered

Last poster hit it right on...be sure you include specific language in your audit report "in compliance with 12 CFR 9, law, and sound fiduciary principles" and make sure the Board of Directors specifically adopts this as a resolution and it is written in the Board minutes. OCC criticized my predecessor for not doing this and I have made sure this gets done every year.

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#205674 - 06/30/04 06:19 PM Re: Frequency of trust audits
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
Quote:

OCC Requirements-Reg 9.9 states-At least once during each calendar year, a national bank shall arrange for a suitable audit (by internal or external auditors) of all significant fiduciary activities, under the direction of its fiduciary audit committee, unless the bank adopts a continuous audit system in accordance with teh paragraph b of this section.




Well, that is a relief, I knew I had heard that somewhere.
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