In a recent FDIC exam, our examiner recommended the Bank develop a model governance policy related to our BSA Software (Verafin) that include levels of authorization and dictate reporting to upper Management or the Board related to Verafin (i.e., number of alerts reviewed, cases, alert efficiency, and significant parameter changes.) Has anyone prepared or been asked for such a policy you can share? I would like to just include a simple section in our current BSA Policy.
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Change is inevitable, except from a vending machine.