Does anyone have an audit program for Reg W that they'd be willing to share? I have never done an audit of this area and our regulators think it should be done.

Other areas I need audit programs for are:

Servicemember's Civil Relief Act
Bank Owned Life Insurance
Web Site Compliance
Regulation L

Any assistance in these areas is greatly apprecited.

Joanne:

Just wondering who your regulators are?

Federal Reserve

I don't have anything written, since it is not really an issue here, but maybe I can get you started.

Reg W deals with transactions with affiliates, so the first thing you need to know is who your affiliates are. Do any of them have any loans with the bank? If so, check rates and terms to make sure there is no preferential (sp?) treatment.

Next, check for things such as lease contracts. Does the bank rent office space from an affiliate? If so, is it at market rates or more favorable to the bank? If higher, then you've got a problem. Documentation and justification of the payment is very important here.

The easiest place to "accidently" violate this reg is with the holding company. Does the bank pay any HC expenses? If so, it could be considered an "unsecured loan" to the HC, if not paid back on the same day. Little things like postage could be bad if the examiner finds them. Check your HC and Bank expense accounts.

BOLI - I'd have your External Auditor include this in his audit. There is so much to this, that I don't want to touch it, as I don't feel qualified.

Website Compliance - I think there is a tool on the BOL Tools page for this. If not, there was a webinar on this subject. Check the BOL Banker's store to order a CD.

Can't help you with the other two, but I hope this helps you some.