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#47879 - 12/10/02 04:13 PM 12 CFR 363 - Attestations
BrendaW Offline
100 Club
BrendaW
Joined: Jun 2001
Posts: 231
Texas
We have OCC examiners here and one point they have brought up is the documetation and review of the documentation for attestations under 12 CFR 363 (our bank is over $500 mil in assets. In specific I am looking at Table 1 to Appedix A which outlines the various federal laws and regulations. Many of the items I already cover under a Reg O review, but there is another section, Dividend Restrictions that needs to be reviewed.

How are other banks handling this requirement? Does your interal auditor review or the compliance officer? Does anyone have a procedure for review they would be willing to share?
_________________________
Brenda W, CRCM

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#47880 - 12/13/02 04:10 PM Re: 12 CFR 363 - Attestations
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
Good question, is there anyone out there with an answer???
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Get your facts first, then you can distort them as you please. - Mark Twain

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#47881 - 12/13/02 04:35 PM Re: 12 CFR 363 - Attestations
Pale Rider Offline
10K Club
Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
Our Finance department prepares the management attestations. Our external auditor prepares an opinion concerning management's attestation. Finally, our internal audit department includes a review of Part 363 in its audit plan. As the compliance officer, I am available for questions but to date I have had very little involvement in this process. It is really the Chief Financial Officer's job to comply with these requirements.
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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