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#2248828 - 02/08/21 03:06 PM Compliance Review Schedule
Community Banker Offline
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Joined: Nov 2008
Posts: 129
Does anyone have a list of regulatory areas that have a required review schedule that they would be willing to share? IE BSA Should be reviewed every 12-18 months etc etc. I am only really concerned with those that have a required schedule. I have a compliance risk assessment that determines the review schedule for other areas. I just want to be sure that I have the right timeframes for required areas. Thank you!

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General Discussion
#2248833 - 02/08/21 03:38 PM Re: Compliance Review Schedule Community Banker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
I am not aware of any hard and fast annual audit requirements except the NACHA ACH audit requirement from a compliance perspective.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2248850 - 02/08/21 05:45 PM Re: Compliance Review Schedule Community Banker
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
The SAFE Act also requires annual independent testing.

From 1007.104: (f) Provide for independent testing for compliance with this part to be conducted at least annually by covered financial institution personnel or by an outside party;

Other than that and ACH, I believe that everything else (including BSA) should be risk-based.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2248851 - 02/08/21 05:47 PM Re: Compliance Review Schedule Community Banker
Community Banker Offline
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Joined: Nov 2008
Posts: 129
Thank you! I have both of those already. What about Flood? Does it not have a stated requirement? Or maybe that was a decision we made internally.

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#2248853 - 02/08/21 05:50 PM Re: Compliance Review Schedule Community Banker
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
Flood does not have an annual audit requirements, but I would think most organizations would justify an annual review, based on risk.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2248863 - 02/08/21 06:06 PM Re: Compliance Review Schedule Community Banker
Community Banker Offline
100 Club
Joined: Nov 2008
Posts: 129
Thank you for your replies!!

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#2248894 - 02/09/21 01:48 PM Re: Compliance Review Schedule Community Banker
Retired DQ Offline
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Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
You should consider performing a risk assessment based on compliance risk for each area of the bank (deposits/loans/ops/etc) and the regs that that impact the area. This will help you determine the frequency of your review, and the risks associated with noncompliance.
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Get your facts first, then you can distort them as you please. - Mark Twain

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