Ouch - this is going to be expensive:
Within 30 days of this Order, the Bank shall retain one or more independent consultants acceptable to the Examiner-in-Charge to supervise and certify an independent review of account and transaction activity (“look-back”) covering areas to be specified in writing by the Examiner-in-Charge.
And
Based upon the results of the look-back, the OCC, at its sole discretion, may expand the scope of the independent review or require a longer look-back period.
Left to the descretion of the EIC is never a good thing.....
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The opinions expressed here should not be construed to be those of my employer:
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