OCC Banks Audit Deadline - July 29?

Good morning! Can anyone cite the chapter and verse from any OCC publications stating that our first annual independant audit is due by July 29th (I believe that's the date)? So far, if it exists, it has remained elusive.

There is nothing in the OCC SAFE act examination handbook that states there is a specific date that this needs to be completed by. It only states it needs to be done annually.

Additionally I can not find anywhere that states a specific date this needs to be done by.

I may be wrong, but I have looked for a long time.

I thought I recalled a thread or email that the OCC has sent some sort of communication out about the 7/29/2012 date. I'll try to find it.

It was a communication from the FRB in Kansas City. I have a PDF of it, but can't seem to copy/paste. If someone knows how I can post a PDF or copy/paste from it, let me know. Otherwise, send me a PM with your email address and I'll email it to you.

Regardless, if you think about it logically, the annual test would be due by 7/29/12 anyway since the drop-dead date to register was 7/29/11. In following that logic, if your bank completed all of the necessary registrations prior to 7/29/11, your annual test should be/have been done by 12 months following the date of your last registration.

In any event your 1st annual test should be completed by 12 months following the mandatory compliance date (7/29).


ETA: FWIW, I did mine in December, and I know other banks did theirs in January. It was built into the audit schedule to coincide with the completion of the annual renewals.

ANBMNCO, Doug, & Dani, thanks for the insight. Dani I agree with you. ANBMNCO, that citation is on Page 14 of the OCC SAFE Act Handbook, where it describes an "annual requirement". I've done some further digging and it appears that this may be one of those issues where the regulators leave it to the bank to decide as long as it's done each calendar year. I've got a msg into our OCC region to get their guidance. I'll post their response here. As it is, I am leaning further away from a hard date in July requirement.