In today’s regulatory environment, safety and soundness is one of the most critical issues with examiners, and having a good loan review program in place is essential to staying on top of credit quality.
Our comprehensive loan reviews provide assistance with loan grading, credit analysis, identification of violations of law and/or policy, as well as furnishing the bank with a listing of technical exceptions identified during our file review. We also analyze and perform our own calculation of the bank’s ALLL in order to test for sufficient reserve balances.
An effective compliance program is no longer a luxury but now a requirement. We provide a full scope compliance review product that covers all of the areas that are both important to examiners as well as critical to risks faced by your bank on a day-to-day basis. Our goal is to provide an audit that is useful towards identifying strengths and weaknesses in the bank’s compliance program, but also to provide a report with enough detail and information to shorten the time examiners spend in the bank.
At a minimum, our full scope compliance audits typically cover the following areas:
• Bank Secrecy Act / Anti-Money Laundering
• Compliance Program Requirements (Regulation H)
• Right to Financial Privacy Act
• Regulation CC
• Regulation D
• Regulation DD (Truth In Savings)
• Regulation E
• Gramm-Leach-Bliley Act Provisions
• Regulation P (Privacy)
• Regulation GG
• Regulation O
• Fair Credit Reporting Act
• Regulation B
• Regulation C
• Flood Disaster Protection Act
• Servicemembers Civil Relief Act
• Regulation Z (Truth In Lending)
• SAFE Act
• UDAAP (Including UDAP)
• Fair Lending
• Community Reinvestment Act
A bank’s review scope can be catered towards their specific needs.
Bank Secrecy Act Audits
Bank Secrecy Act compliance remains one of the most critical issues with regulators, and does not appear to be waning in importance anytime in the future. Meeting the continuously evolving requirements has become a very cumbersome and complex process.
We cover all aspects of Bank Secrecy Act in our reviews and use the FFIEC Bank Secrecy Act/Anti- Money Laundering (BSA/AML) Examination Procedures as our checkpoint. Our typical BSA/AML audits include, at a minimum, testing in such areas as Currency Transaction Reports, Suspicious Activity Reports, OFAC, funds transfers, Customer Identification Program, Anti-Money Laundering monitoring, 314(a), and Money Service Business reporting and tracking.
Fair Lending Audits
Our Fair Lending audits consist of different facets of comparisons to arrive at conclusions, similar to the methods recommended in the Interagency Fair Lending Examination Procedures. Our goal is to not only provide an analysis of the bank’s consumer loan portfolio, but to educate bankers regarding lending practices that could inadvertently be considered disparate impact or lead to accusations of discrimination.
Allowance For Loan & Lease Loss Methodology
We have been performing an independent review and calculation of the bank’s ALLL adequacy since the early 1990s. Our program has been adapted over the years as new guidance has been released, and has always been considered acceptable by the regulating bodies. This calculation is a part of our loan review program, and includes recommendations for proper impairment reserves, if applicable.
We have assisted banks for years with the asset quality side of a due diligence for a potential acquisition, or in the area of valuations of loan packages for purchase. We have ample experience to provide the level of expertise needed in this area.