As Compliance Officer, I perform compliance monitoring for the bank, and report the results to the Audit Committee of the BOD. Needless to say, the monitoring reports are quite detailed, and clearly indicate the nature of any violations noted. I also work with other areas of the bank to take any appropriate corrective action.

One of the first things the examiners ask for when they come in is the minutes of the AC meetings and any compliance monitoring workpapers, which gives them a plain view of the various exceptions and violations found through our internal monitoring efforts. Is there any type of finding that you can withhold from an examiner when
they request this type of information, or are they privy to everything? Where do you draw the line when preparing your presentations for the Audit Committee or BOD? It seems that you have to divulge what you found. Can anyone provide some insight?

In response to your regulator question: Give them everything they ask for, because if they find it, through their own review, you will be in hot water.
Regarding committee reports, I report all of my findings. I try to leave the names out, by designating department (eg: Loan officer), but if I am asked, I give the name of the violator.
It's also known as CYA... It's tough to be that way, but that's what I'm paid for.
Only MHO. I am sure others have a more creative reply.

You can report conclusions without slipping your neck in a noose. Instead of reporting details, generalize your findings. Even though the details may be in the workpapers, examiners may not take the time to look at all of it. Monitoring is a management tool, not a regulatory requirement (except for BSA), so who's to say what's enough and what needs to be reported.

So, you're thinking, the examiners will criticize me for not making their job easier? Let them "recommend" increased monitoring. If your CEO and board thank the examiners for their suggestions and promise to take them under advisement, that's all that's required. After considering the cost/benefit ratio, your management may conclude that it is quite happy with the status quo.

I don't believe you can withhold anything from your examiner. If not specifically asked for, you don't have to volunteer information, but you don't withhold.

Part of what they are looking at is whether or not your compliance program is working. Thorough, risk-based audits with violations noted, corrected if possible and ensuring that steps were taken to prevent a recurrence of the violation is partially what you are graded on. Your bank should see this process as being in their best interest as well.

How you word your reports is up to you. A specific person responsible may have to be named if you felt it appropriate, such as in a fair lending exam. It may also be that the procedure, not the person was at fault. No need to name names in that case.

Consider too, in the event of a suit, are your workpapers protected from discovery? This may be done through attorney-client privilege or your state's law may protect them under certain conditions such as the errors were corrected. You should be aware of the possibilities.

I told you there were more eloquent guys out there!

While agree with the posts that advise not to withhold information, I have to say that virtually everything the examiners cited us for in our last exam came straight from my (detailed) workpapers. I felt like I had given them a map to the buried treasure. I also felt that they should have split their exam pay with me, since I had done most of their work for them.

Ask that they indicate the violations noted were found internally and corrective measures have been taken. At least you'll get points for that. The alternative is that they dig as deep as they can for as long as they're there. I'd just as soon have them piggy back off my audits after they validate the findings.

This doesn't mean you hold back in your audit schedules, it means you write good audit and correct the errors.

So the exam findings would have been -0- if you had not done the monitoring? Sounds like you would be better off not creating workpapers. Once again, how much of what kinds of self-reviews, workpapers and reports are a management call.