We are undergoing a FDIC Safety and Soundness exam which includes BSA ...on the request list, they asked for "Exemption List and the most recent date the Board reviewed and approved the exemptions ..." I am confused, I didn't realize that the Board had to approve exemptions. I searched the reg and cannot find this anywhere. Am I blind, or am I looking in the wrong place?

Help!!!

I'm not aware of any requirement to have the Board approve the exemption list either. The board must approve the BSA policy, but that is it. Rest easy and good luck. Keep us posted on the exam.

Thank you ...I really thought I had gone crazy as I have been in the biz for over 20 years and had never been asked that one.

Have a good evening ...you know I'll be sleeping well tonight!

A random thought -- Could it be possible that your BSA policy calls for board approval of the exemptions? If that's the case, the examiner request was appropriate.

And, I'd suggest you work toward removing the requirement from policy. The exemption list should be referred to in policy, but managed by management.