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Reporting MSB/High Risk Accounts to the Board

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I've been told by our independent auditor that MSB/High risk accounts must reported to the Board. Is this true?

No, it is not. The existence of high risk accounts is factored into your risk assessment. Obviously, you cannot do that if you have not identified them; i.e., made up a list. The regulators will ask you for a copy of the list in the request letter you receive prior to an on-site BSA examination.

However, there is no regulatory suggestion that the actual list be reported to the board. My opinion is that it's purely an upward delegation of responsibility; i.e., I strongly disagree that it is necessary or appropriate.

First published on 1/9/06

First published on 01/09/2006

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