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#61499 - 02/15/03 02:33 PM
Re: Privacy Act - FDIC Exam
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Diamond Poster
Joined: Feb 2001
Posts: 2,245
US of A
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Does anybody ever really "pass" an exam? I think it's more like, "You made it this time, pal, but we'll be back soon."
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"If you want to tell people the truth, make them laugh, otherwise they'll kill you." ~ Oscar Wilde
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#61501 - 02/16/03 12:24 AM
Re: Privacy Act - FDIC Exam
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Anonymous
Unregistered
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Ipso, I only wish I could say the same thing about the FDIC. Our experience with our FDIC GLBA 501(b) exam was less than "we're here to help."
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#61503 - 02/17/03 02:27 PM
Re: Privacy Act - FDIC Exam
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Junior Member
Joined: Jun 2002
Posts: 39
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As a relatively new Privacy Officer, I just can't wait for my first Privacy Exam!!!
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I don't know all the answers.... but I know where to get them!
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#61504 - 02/17/03 02:56 PM
Re: Privacy Act - FDIC Exam
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10K Club
Joined: Jul 2001
Posts: 83,396
Galveston, TX
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I concur with Bonnie - based on what are they requiring you to maintain this type of documentation. Sounds like they are making things up!
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#61505 - 02/17/03 03:54 PM
Re: Privacy Act - FDIC Exam
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Power Poster
Joined: Oct 2001
Posts: 5,564
Clintonville, WI, USA
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Bonnie, I wonder how our exam will go. We started using new account review forms, and we have a box to check to say we ran the name against the OFAC list. Many times, the personal banker will make a notation next to the box, like OK or No Match Found. We haven't been copying the screen, but we figured the check in the box reminds our people to do it and idicates that they did it.
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Member of the National Sarcasm Society - like we need your support!
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#61507 - 02/17/03 09:14 PM
Re: Privacy Act - FDIC Exam
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10K Club
Joined: Jul 2001
Posts: 83,396
Galveston, TX
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I don't think that only the big banks should fight back on this one. There is no regulatory retention requirement for proof of compliance. Therefor, I believe it would fall under all the other regulatory requirements that only require proof through adequate procedures - i.e., delivery of early ARM disclosures for example. I don't think any bank should stand still for examiners making up documentation rules as they go along. Unless they found that you had a hit show up during your periodic existing account scrub that should have been caught at account opening, I think you can use that to show that your current procedures are affective.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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