08/25/2003
by Eileen Shannon, Independent Audit Associates, Inc.
08/25/2003
We have separated our Customer Information Security Review into "two" sections - one relating to our information system (computers, software,etc,) and one for security of the customer information (documents, information we give out over the phone, etc). Can anyone recommend an audit program relating to the security of customer information?
08/11/2003
We need clarification as to how to handle the titling of IRAs after the owner has died and the beneficiary is electing to take distributions from the IRA instead of closing it out and treating it as their own. In the past, we completed the Election of Beneficiary Form for IRS reporting. The confusion comes in because some think the IRAs "must be closed out" and I don't think that is necessarily true. I think in some cases they just need to be retitled, especially in situations where, for example, a spouse would elect to take life expectancy payouts.
08/04/2003
Our last Deposit Controls audit cited us for not following a good procedure for address changes. Our system produces a report that shows if anyone has accessed a customer's file. Employees are also required to fill out a form any time they make a change to the customer's file. To your knowledge, are we required to have a customer sign a form to show that any of their info was changed? If so, do they sign for address changes only or should they sign for any type of change (address, phone, employment...maybe date of birth or Social) to their Customer Information file?
04/21/2003
When establishing a compliance department, who should the employees report to? Who should have oversight to the review/audit their work? Should we have an audit committee or should there be a separate committee? If a separate committee is established, would it need to include at least one board member? I am trying to define the difference between a compliance officer that has direct involvement in the implementation of policy and procedures, reporting (i.e., also serves as the CRA officer) and conducting reviews. I see the audit department as having a responsibility to audit the compliance department's work. We are a small bank just crossing the half billion mark. Staffing is an issue and most employees wear multiple hats.
04/07/2003
I am working on processing dormant certificate of deposits for the first time. I need a confirmation on the definition of a dormant certificate of deposit. Is it considered dormant due to inactivity for a year from the original maturity date?
02/03/2003
I'm looking for justifications to convert to a Proof of Deposit system, from an online environment.
02/01/2003
Question: It seems as if we will never get all the questions answered on the completion of CTRs. Ours is the completion of a CTR on deposits to joint ownership deposit accounts.
01/06/2003
Although I have read through most of the information on the site referring to funeral trust accounts, there is always another question that comes up. We have a branch that wants to have the funeral home sign a letter authorizing all the CDs in place of having to sign a signature card for each one. Would any problems be created if we adopted this practice? In addition, any other suggestions regarding a good procedure for opening funeral trust accounts would be appreciated.
12/02/2002
I need some ammo to use, such as the 12 CFR gauge or more powerful. My lending executive officer has authorized for use in a consumer transaction an application that does not meet any of the requirements found in Appendix B of Sec. 202 of Reg. B. For example, no space for Co-applicant information; no disclosure for other income (alimony, child support or other maintenance income; no statement as the correctness of the information above the applicant signatures; no authorization for credit verification, or employment verification, etc.; and no lines for applicant(s) signatures. That's right, consumer application without applicant's signatures. When the new operations VP came on board in 1980, he brought along the Lending Officers Worksheet(WKS). The sole purpose of the WKS was to be used to document credit requests in the case of business and corporate use. Ten years later one lending officer began the practice of using the form as a consumer application as a way to cut corners. That officer is still here. I have made recommendations during my Fair Lending Audit year after year to cease using the form as an application for credit. I have used Reg B as my basis of argument to no avail. I think I need some big guns, such as, law suits, where banks lost money due to technicalities where the documents are not signed properly. Any suggestions or examples would be appreciated.