I am working on an IRA audit. I have the program, but the only thing that I don't have is the guidelines on how to approach the required distributions which are required to be taken due to age. Generally we notify the customer and they are responsible for taking the distribution after the 70 1/2 minimum distribution. Do you have any guidance as to the responsibilities of the bank? After we send out a letter, how often should reminders be sent and what are the steps if the client does not respond?
What individual risk assessments is a bank expected to perform? How do the individual risk assessments fit together with an "enterprise risk assessment"?
After an account owner dies can that account be left open and put in the name of the POD?
I plan to include a recommendation in my annual report to change the current reporting structure for the Security Officer. Presently, I report to the VP of Retail Operations. I am seeking references to cite that advise the bank security reporting structure should be in other areas such a finance, risk, administration, but not through retail because of the apparent potential for downward influences and the need for independence.
During our compliance audit we noticed that periodically hold notices are being provided to customers for exception holds that have both exception and case by case checked. Do we need to have our staff send out revised forms that have only the exception hold box checked?
How in-depth should the training be for the Board of Directors in BSA? Is a general overview of BSA/AML/CIP along with an overview of the procedures in place sufficient for compliance?
I am an auditor of a bank and did the branch audit yesterday. What are the requirements under CRA for the notice to be posted in a branch of a bank which is OTS regulated? I have a copy of the notice and want to make sure that it complies with the Reg.
During a recent FDIC audit, we were told that returned deposit notices involving checks that had been converted into IRD's needed a Check 21 disclosure notice enclosed with the notification/check. Our account opening disclosures already have the Check 21 disclosures included with them. Is this correct or were they mistaken?
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