We're in the process of gathering information for a BSA exam in October. The pre-exam request list and questionnaire ask for the date the board approved the exemption list. Maybe I've totally lost it, but I thought that was no longer required. Although I haven't reviewed the file from the last exam, I'm almost positive that was not part of the request on the previous exam. We are FDIC regulated - anyone out there had a recent exam that can provide insight? Thanks!

Our list isn't approved by the board. We were examined a few months ago and it wasn't questioned. My appointment as the BSA officer, however, required board approval.

There is no written requirement in the regulation that the Board approve the exemption list. If the examiners write you up on this, I would ask them to show you were in the regulation this is required. I'm wondering if they are just looking for a list of exempted customers.

We just went through an FDIC BSA exam. They wanted to see the exemptions and documentation, but nothing has ever been mentioned about board approval. It not required!

Check your policy to be sure that it does not say that the list will be board approved. They may be testing your policy.

I'm not sure what FDIC district you're in, but the Chicago FDIC is putting on a conference call on September 27th at 10:00 Central (11:00 Daylight Savings Time) concerning BSA. These generally last about an hour and a half. We have several people here who will be listening in.

Thanks everyone! I reviewed the request list again to make sure I didn't misread it and it does say a copy of the exemptions AND the date it was last board approved. We are not in the Chicago district, in the Dallas district, so I suppose the BSA conference call would not be available to us. Thanks anyway!

Penny, did you check your BSA policy to see what it said.

Our BSA Policy does not include that the exemption list will be approved by the board. Thanks for thinking of that. Unless it was in the policy AND the examiners had noted that from the last exam, they do not have any documents yet, so would not have that information at this point even if it was in the policy, but that is a good point.

In that case, I agree with hawksfan. Ask them to show you where they are relying on this request.

Did anything ever become of this? I'm facing the same thing, the FDIC wants a copy of the exempt list and the date the Board last reviewed and approved the exemptions.

Thanks.