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#1721999 - 07/20/12 06:54 PM Annual audit
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
I keep seeing posts that the annual audit of SAFE ACT should be done by July 29th, but since finding out bankersonline is offering an Aug 8th webinar, I'd much rather wait until I've veiwed the webinar. Do you think examiners would have a problem with that?

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S.A.F.E. Act Forum
#1722040 - 07/20/12 07:54 PM Re: Annual audit Southern gal
osucpa Offline
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Joined: May 2011
Posts: 1,406
No.

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#1722162 - 07/22/12 11:48 AM Re: Annual audit Southern gal
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Do you think examiners would have a problem with that?

I would say yes. The requirement is the requirement.
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#1722692 - 07/24/12 02:41 PM Re: Annual audit Southern gal
Irishguy Offline
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Irishguy
Joined: Aug 2008
Posts: 613
Kentucky
You could always use the CFPB's examination procedures to comply with the July date and then if you find out that you should be looking at other elements from the BOL course, you could go back and audit those areas after the webinar. Just a thought.

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#1722960 - 07/24/12 11:43 PM Re: Annual audit Irishguy
BabyB Offline
New Poster
Joined: Sep 2010
Posts: 16
You will have to forgive me for asking, but, I can not locate the requirement within the Act that the Audit needs to be completed by July 29th. Can you please point me to where this specific date requirement is located?
Last edited by BabyB; 07/24/12 11:43 PM.
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#1722963 - 07/25/12 12:24 AM Re: Annual audit Southern gal
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It is one year from the 7/29/2011 deadline for compliance. The one easy to find written statement is from the Kansas City FRB:

Furthermore, the SAFE Act rule requires a federally-regulated institution to conduct an annual test to review its compliance with the rule. Such independent compliance activities may
be conducted by an institution's internal audit function, compliance (or similar) function, or by an outside party. The deadline date for completion of the 2012 test by Federal Reserve supervised institutions is July 29,2012, which is one year from the close of the initial registration period for federal MLOs. Thereafter, institutions are required to independently test for compliance with the rule at least annually.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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