And if it's stated in your policy as a requirement, it would be appropriate for an auditor or examiner to cite the bank if it failed to follow its own internal controls. And frankly, when auditors and examiners see one unenforced control, their radar is up looking for other unobserved controls.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8