Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to: (a) detect irregularities in the Bank's operations; (b) determine the Bank's level of compliance with all applicable laws, rules and regulations; (c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification; (d) ensure adequate audit coverage in all areas; and (e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives. (2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article. (4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed. (5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party. (6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions. (7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf. (8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 3 contracts
Samples: Banking Agreement, Banking Agreement, Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) daysdays of the date of this Agreement, the Board shall adopt, implementand the Bank, subject to Board review and monitoring, shall implement and thereafter ensure Bank adherence adhere to an independent, internal audit program to correct the internal audit deficiencies described in the most recent XXX. The independent, internal audit program shall comply with OCC Bulletin 2003-12, Interagency Policy Statement on Internal Audit and Internal Audit Outsourcing, (March 17, 2003) and shall include an annual written audit plan using a risk based approach sufficient to achieve the objectives outlined in this Article, including requirements for written reports to the Board Audit Committee at least quarterly. The program shall, at a minimum, include standards for the depth and scope of audits, sampling and transaction testing, investigation of root causes, follow-up on exceptions, elevation of findings to the Board Audit Committee, validation of corrective actions, and an assessment of internal audit effectiveness, staff levels, and staff performance. The independent, internal audit program shall be sufficient, at a minimum, to:
(a) detect and identify the root causes of irregularities and weak practices in and other exceptions to the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules rules, regulations and regulatory guidance, including consumer protection laws, regulations, and regulatory guidance;
(c) assess and report on the effectiveness of policies, procedures, controls, risk management practices, and management information systems;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) adequately and timely evaluate the efficiency and effectiveness of the Bank’s corporate governance, internal controls, and risk management functions;
(f) ensure adequate audit coverage in all areastimely and appropriate follow-up on identified deficiencies, weak practices and other exceptions to ensure timely implementation, verification and documentation of corrective action; and
(eg) establish an annual audit plan using a risk based approach sufficient review and evaluate the Bank’s actions taken to achieve these objectivescomply with this Agreement.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, including with respect to both the qualifications, experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above in this Article shall be independent, qualified and report directly to the BoardBoard Audit Committee, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed in writing directly with the Board Audit Committee and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy correct deficiencies cited in audit reportsreports and shall maintain a written record describing the deficiency, the projected corrective action, and the status of the corrective action. The Board shall ensure that internal audit management provides detailed written explanation in those circumstances, if any, where the deficiencies cannot be remedied, and that auditors the audit staff maintain a written record describing those actions. The Board shall provide for a timely, independent, written follow-up for any uncorrected deficiencies.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank OCC examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 2 contracts
Samples: Banking Compliance Agreement (Trustco Bank Corp N Y), Banking Compliance Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program covering all areas of the Bank, sufficient to:
(a) detect irregularities and weak practices in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's ’s adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party, including any individual who is a director.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners The Comptroller shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerComptroller for review and determination of no supervisory objection.
Appears in 2 contracts
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 2 contracts
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, review and thereafter ensure Bank adherence to an independent, revise its independent internal audit program to ensure it is sufficient to:
(a) detect irregularities and weak practices in the Bank's Association’s operations;
(b) determine the Bank's Association’s level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's Association’s adherence to established policies and procedures, with particular emphasis directed to the Bank's Association’s adherence to its loan policies concerning underwriting standards and problem loan identification and classificationconcerning:
(i) adherence to credit approval conditions in the terms provided to borrowers;
(dii) ensure adequate audit coverage proper separation of duties in authorization of deposits and wires to fund loans;
(iii) verification that the borrowers and guarantors that were evaluated in the loan approval documents are consistent with those in the actual loan agreements and guarantees obtained;
(e) adequately cover all areas;
(f) determine conclusions and ratings on the quality of the areas audited; and
(eg) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board or its Audit Committee shall evaluate the audit reports of any party providing services to the BankAssociation, and shall assess the impact on the Bank Association of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board its Audit Committee, shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actionsthe deficiency, the projected corrective action, and the status of the corrective action.
(75) The audit staff shall have access to any records necessary for evaluate in writing the proper conduct of its activities. National bank examiners shall have access to all reports and work papers effectiveness of the audit staff corrective action and any other parties working on its behalfrecommend additional corrective actions, as necessary.
(8) 6) Upon adoption, a copy of the revised internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 2 contracts
Samples: Banking Agreement, Banking Agreement (Beacon Federal Bancorp, Inc.)
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank Association adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's Association’s operations;
(b) determine the Bank's Association’s level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's Association’s adherence to established policies and procedures, with particular emphasis directed to the Bank's Association’s adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage review and provide an opinion regarding whether regulatory reports beginning with the quarter ending September 30, 2012, contain “material misstatements” within thirty (30) days of filing; for purposes of this Article, “material misstatements” has the same meaning as the term is used in the SEC’s Staff Accounting Bulletin No. 99 on Materiality (“SAB 99”).
(f) adequately cover all areas; and
(eg) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the BankAssociation, and shall assess the impact on the Bank Association of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank Association has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners The Comptroller, through his authorized representatives, shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) 60 days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's ’s adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage review and provide an opinion regarding whether regulatory reports beginning with the quarter ending June 30, 2009 contain “material misstatements” within thirty (30) days of filing; for purposes of this Article, “material misstatements” has the same meaning as the term is used in the SEC’s Staff Accounting Bulletin No. 99 on Materiality (“SAB 99”);
(f) adequately cover all areas; and
(eg) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(43) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) daysdays of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, independent internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules rules, and regulations, with particular emphasis on affiliate and insider transactions;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to on the Bank's ’s adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) adequately cover Bank activities to maintain or improve the efficiency and effectiveness of the Bank’s risk management, internal controls, and corporate governance functions;
(f) ensure adequate audit coverage timely follow-up on identified deficiencies to ensure their correction;
(g) comply with the standards contained in all areasOCC Bulletin 2003-12, “Interagency Policy Statement on the Internal Audit Function and its Outsourcing”; and
(eh) establish ensure adherence to an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part The Board shall ensure that the internal audit program is independent. The person responsible for implementing the internal audit program described above shall report directly to the Board, who shall have the sole power to direct his/her activities. All reports prepared by the audit staff or audit firm shall be filed directly with the Board and/or Board Audit Committee (comprised of this at least two external directors) and not through any intervening party.
(3) The Board shall ensure that the internal audit programprogram is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of individuals employed.
(4) The Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the all deficiencies identified by audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and/or regulatory agencies are appropriately monitored and not reported through any intervening partya formal tracking report.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy correct any deficiencies cited in audit reports, reports and that auditors shall maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports deficiency, the projected corrective action, and work papers the status of the audit staff and any other parties working on its behalfcorrective action.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within The Board shall cause, within ninety (90) days, a revision to the Board shall adopt, implement, and thereafter ensure Bank adherence to an Bank’s independent, internal audit program. The revised internal audit program shall conform to the guidance contained in the Internal and External Audits booklet, M-Aud, of the Comptroller's Handbook, and be sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) determine the accuracy of the Bank’s books and records, including the timeliness of account reconciliation;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in all areas; and
(ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board Board, or a committee thereof, shall evaluate the audit reports of by any party providing auditing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that cause the Bank has to have the processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is shall be supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is shall be independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that or a committee thereof, which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board Board, or a committee thereof, and not through any intervening party.
(6) All audit reports shall be in writing. The Board Board, or a committee thereof, shall ensure direct that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerDirector.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program. In formulating this program, the Board shall refer to the Internal and External Audit booklet of the Comptroller's Handbook. The program shall be sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board Board, or a committee thereof, shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an a qualified and adequately staffed department or qualified outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the BoardBoard or its designated audit committee, that shall have the sole power to direct their activities. All reports prepared by the audit staff auditor(s) shall be filed directly with the Board and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors auditor(s) maintain a written record describing those actions.
(76) The audit staff Board shall have access ensure that the Bank has processes, personnel, and control systems to any records necessary for ensure implementation of and adherence to the proper conduct of its activities. National bank examiners shall have access program developed pursuant to all reports and work papers of the audit staff and any other parties working on its behalfthis Article.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety thirty (9030) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an a new independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules to adequately monitor and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to internal audit services provided by its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate outsourced internal audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bankservice provider, and shall assess the impact on the Bank of any audit deficiencies cited in such reports. The Bank’s internal audit program shall be consistent with the requirements contained in OCC Bulletin 98-1, Interagency Policy Statement on Internal Audit and Internal Audit Outsourcing and the Internal and External Audits booklet (June 2000) of the Comptroller’s Handbook.
(32) The Board shall ensure that the Bank has processes, personnel, and control systems systems, including a qualified and accountable Bank officer responsible for oversight of the program, to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(53) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, or a committee thereof, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(64) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(75) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 6) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areas; and
(ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners The OCC shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areas; and
(ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports. The Board shall also ensure management addresses audit deficiencies in a timely manner.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, Board that shall have the sole power to direct their activities. All audit reports prepared by the audit staff shall be filed directly with the Board and not through any intervening partyBoard.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners Bank Examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independentadequate, internal audit program. The program shall be designed in light of the comments on developing and maintaining an effective internal audit function found in the “Internal and External Audits” booklet of the Comptroller’s Handbook and shall focus sufficient toattention on the following factors:
(a) detect irregularities in provide the Bank's operationsInternal Auditor with appropriate training, both internal and external, to ensure the Internal Auditor is competent and qualified to effectively administer the audit function;
(b) improve audit workpaper documentation to include an adequate audit trail;
(c) determine the Bank's level of compliance with all applicable laws, rules regulations, and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classificationOCC issuances;
(d) ensure adequate audit coverage in all areas; and, with focus on high-risk areas, and periodically review all audit programs for changes/updates;
(e) establish removal of all operational responsibilities from the internal audit function; and,
(f) expansion of the asset liability management audit to include a review of data integrity and an annual audit plan using a risk based approach sufficient to achieve these objectivesoverview of internal controls over the preparation and reporting process.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(64) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(75) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Compliance Agreement
Internal Audit. (1) Within ninety sixty (9060) daysdays of the date of this Agreement , the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areasoperational areas of the Bank; and
(ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(64) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(75) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 6) Upon adoption, a copy of the internal audit program shall be promptly submitted provided to the Assistant Deputy Comptroller.
(7) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) daysdays of the date of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, independent and comprehensive internal audit program sufficient tothat:
(a) detect irregularities includes procedures to assist in the Bank's operationscompleting internal operations audits;
(b) determine detects irregularities and weak practices in the Bank's ’s operations;
(c) determines the Bank’s level of compliance with all applicable laws, rules rules, and regulations;
(cd) evaluate assesses and reports the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(e) evaluates the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(df) ensure adequate establishes a line of communication for audit coverage in all areasreporting issues between the internal auditor, audit committee, and Board of directors;
(g) ensures audit work papers and documentation of conclusions provide a meaningful audit trail and validation for findings and recommendations;
(h) ensures timely management responses and corrective actions on identified weaknesses; and
(ei) establish establishes an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firmdepartment, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons person(s) responsible for implementing the internal audit program described above shall report directly to the BoardBoard and/or Board Audit Committee (comprised of at least two (2) external directors), that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and/or Board Audit Committee and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an improve its independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) identify and report on root cause of any deficiencies to ensure successful remediation
(e) ensure adequate audit coverage in all areas;
(f) ensure audit follow-up on any outstanding internally identified issues or prior regulatory or external findings; and
(eg) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any regulator or third party providing services to the Bank, and . The Board or Audit Committee shall assess the impact on the Bank of any audit deficiencies cited in such reports, obtain management’s response, and followup to ensure that audit deficiencies have been effective.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions. This record should include management’s response and timeframes for corrective action.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners Bank Examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement (First West Virginia Bancorp Inc)
Internal Audit. (1) Within ninety (90) daysBy March 31, 2019, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program that comports with the standards for Internal Audit Systems set forth in Section II.B of the Interagency Guidelines Establishing Standards for Safety and Soundness, Appendix A to 12 C.F.R. Part 30. Refer to the “Interagency Policy Statement on the Internal Audit Function and Its Outsourcing” (OCC Bulletin 2003-12) for guidance. The internal audit program shall be sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable insider and conflicts of interest laws, rules and regulations;
(c) evaluate assess and report the Bank's adherence to established policies and effectiveness of policies, procedures, with particular emphasis directed controls, and management oversight relating to the Bank's adherence to its loan policies concerning underwriting standards accounting and problem loan identification and classificationfinancial reporting;
(d) ensure adequate audit coverage in adequately cover all areasaspects of the Bank’s operations, including but not limited to internal controls, corporate governance, overdraft management, insider activities, conflicts of interest, and call report preparation; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this internal audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the internal audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank Bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program immediately shall be promptly submitted to the Assistant Deputy Comptroller.
(8) The Board shall ensure that the Bank has processes, personnel, control systems, and corporate and risk governance to ensure implementation of and adherence to the internal audit program developed pursuant to this Article.
Appears in 1 contract
Samples: Compliance Agreement
Internal Audit. (1) Within ninety thirty (9030) days, the Board shall adoptadopt changes to the Bank’s internal audit program, implement, and the Bank shall implement and thereafter ensure Bank adherence to an independent, a revised independent internal audit program sufficient tothat is consistent with the Internal Audit Section of the Office of Thrift Supervision (“OTS”) Handbook, Section 355(February 2002), the Standards for Internal Audit Systems at 12 C.F.R. Part 170, Appendix A, and any subsequent OCC guidance that includes at a minimum:
(a) detect irregularities in development and maintenance of a risk-based audit plan, covering both financial and non-financial areas of the Bank's operations, with risk assessments to support the frequency and scope of reviews for each area covered by the plan;
(b) determine well documented procedures and testing to support the scope of each audit that adequately address internal controls, systems and the Bank's level of ’s compliance with all established policies and procedures, and applicable laws, rules regulations and regulationsregulatory guidance;
(c) evaluate an assessment of the Bank's adherence to established policies and effectiveness of policies, procedures, with particular emphasis directed controls, and management oversight relating to the Bank's adherence to its loan policies concerning underwriting standards accounting and problem loan identification and classificationfinancial reporting;
(d) ensure adequate audit coverage auditors with the knowledge, experience and skills (including in specialty areas such as Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) compliance and information technology and security), to detect weaknesses, irregularities and instances of noncompliance, and conclude on the overall effectiveness of the Bank’s internal controls, systems, policies, procedures and risk management practices in all areasareas covered by the audit plan; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectivesexception tracking reports that include all audit recommendations and regulatory findings, with identified timeframes for follow-up.
(2) As part of this The Audit Committee shall annually review and approve the audit program, plan to ensure that audit risk assessments prepared by management appropriately reflect any changes in the Board Bank’s operating environment and continue to support a risk based plan.
(3) The Audit Committee shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board Audit Committee shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(75) The audit staff Audit Committee shall have access to any records necessary for the proper conduct keep minutes of its activities. National bank examiners meetings and shall have access report to all reports and work papers of the audit staff and any other parties working on its behalffull Board at least quarterly, or more frequently if warranted.
(8) 6) Upon adoptioncompletion, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerADC.
Appears in 1 contract
Internal Audit. (1) Within ninety sixty (9060) daysdays of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, independent and comprehensive internal audit program sufficient tothat:
(a) detect irregularities includes procedures to assist in the Bank's operationscompleting internal operations audits;
(b) determine detects irregularities and weak practices in the Bank's ’s operations;
(c) determines the Bank’s level of compliance with all applicable laws, rules and regulations;
(cd) evaluate assesses and reports the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(e) evaluates the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(df) ensure adequate establishes a line of communication for audit coverage in all areasreporting issues between the internal auditor, audit committee, and board of directors;
(g) ensures audit work papers and documentation of conclusions provide a meaningful audit trail and validation for findings and recommendations;
(h) ensures timely management responses and corrective actions on identified weaknesses; and
(ei) establish establishes an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) The Board’s compliance with Paragraph (1) of this Article shall include the development of an audit policy and the performance of a Bank-wide risk assessment to guide the Bank’s development of the audit scope and annual coverage.
(3) As part of the audit program required by this audit programArticle, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and/or Board Audit Committee (comprised of at least two external directors) and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Compliance Agreement
Internal Audit. (1) Within ninety (90) days, the Board Board, or a designated committee that includes a outside director with relevant banking experience, shall adopt, implement, and thereafter ensure Bank adherence to an independent, risk based internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;; and
(c) evaluate assess and report the Bank's adherence to established policies and effectiveness of policies, procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards controls, and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectivesmanagement oversight.
(2) As part of this audit program, the Board Board, or a designated committee that includes an outside director with relevant banking experience, shall evaluate the audit reports of any party providing services to the Bank, and shall shall:
(a) assess the impact on the Bank of any audit deficiencies cited in such reports;
(b) assess, through the review of workpapers or some other formal qualitative means, the quality of internal audit being provided to the Bank; and
(c) ensure significant findings are included in the final audit report; isolated or immaterial findings must be discussed with management and accompanied by documentation indicating that the finding was discussed and rationale for dismissing the finding as an audit conclusion.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(75) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerComptroller for supervisory non-objection. Immediately upon receiving a determination of supervisory non-objection, the audit program shall be implemented.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areas; and
(ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board or its Audit Committee shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the BoardBoard or its Audit Committee, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be in writing and filed directly with the Board or its Audit Committee and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those the deficiency, the projected corrective action, and the status of the corrective action.
(6) The audit staff shall evaluate in writing the effectiveness of the corrective action and recommend additional corrective actions, as necessary.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerDirector.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program consistent with Subparts A and B of Section II, “Operational and Managerial Standards,” of Appendix A to 12 C.F.R. Part 170— Interagency Guidelines Establishing Standards for Safety And Soundness. The internal audit program shall be sufficient to:
(a) detect irregularities and weak practices in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areas; and
(ef) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party, including any individual who is a director.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners The Comptroller’s Examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety one hundred and twenty (90120) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) evaluate the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(e) determine whether the Bank is filing accurate and correct Call Reports;
(f) ensure adequate audit coverage in all areas, including Bank Secrecy Act compliance, consistent with the requirements of Articles VII and VIII; and
(eg) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Audit Committee required to be appointed by the Board shall pursuant to Article III of this Agreement (“Audit Committee”) shall: evaluate the audit reports of any party providing services to the Bank, and shall ; assess the impact on the Bank of any audit deficiencies cited in such reports; and report its findings to the full Board.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board Board, through its Audit Committee, shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the BoardAudit Committee, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board Audit Committee and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners Bank Examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Merger Agreement
Internal Audit. (1) Within ninety (90) daysBy December 31, 2018, the Board shall must adopt, implement, and thereafter ensure Bank the Bank’s adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting, with particular emphasis directed to carrying out changes in the Bank’s Allowance for Loan and Lease Losses (“Allowance”) methodology throughout the Bank’s reporting process and to ensuring that the Board has appropriate financial reporting information;
(d) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areas; and
(ef) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this the Bank’s internal audit program, the Board shall must evaluate the all audit reports of any party providing services to the Bank, and shall must assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall must ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall must ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall must ensure that the audit program is independent. The persons audit staff responsible for implementing the internal audit program described above shall must report directly to the Board, that shall which must have the sole power to direct their activities. All reports prepared by the audit staff shall must be filed directly with the Board and not through any intervening party.
(6) All audit reports shall must be in writing. The Board shall must ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall must have access to any records necessary for the proper conduct of its activities. National bank examiners shall must have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall must be promptly submitted to the Assistant Deputy ComptrollerADC.
Appears in 1 contract
Samples: Compliance Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adoptreview, implementrevise, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage review and provide an opinion regarding whether regulatory reports beginning with the quarter ending September 30, 2010, contain “material misstatements” within thirty (30) days of filing; for purposes of this Article, “material misstatements” has the same meaning as the term is used in the SEC’s Staff Accounting Bulletin No. 99 on Materiality (“SAB 99”).
(f) adequately cover all areas; and
(eg) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bankreports, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerADC within ten (10) days.
(8) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program program, sufficient in scope and frequency, to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate evaluate, on a quarterly basis, the audit reports of any party providing audit services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety thirty (9030) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to adopt an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's ’s adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areas; and
(ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the BoardBoard or a committee thereof, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners Bank Examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon 7) Within five (5) days of adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and ensure Bank adherence to the audit program.
Appears in 1 contract
Samples: Banking Compliance Agreement
Internal Audit. (1) Within ninety (90) daysBy December 31, 2018, the Board Bank shall adoptrevise and after adoption by the Board, implement, and thereafter ensure Bank adherence to implement an independent, internal audit program sufficient to:
that is consistent with safe and sound standards for internal audit. Refer to (ai) detect irregularities the standards for Internal Audit Systems set forth in Section II.B of the Interagency Guidelines Establishing Standards for Safety and Soundness, Appendix A to 12 C.F.R. Part 30; (ii) the guidance set forth in the Bank's operations;
“Interagency Policy Statement on the Internal Audit Function and Its Outsourcing” (bOCC Bulletin 2003-12); and (iii) determine Internal and External Audits booklet, M-AUD, of the Bank's level of compliance with all applicable laws, rules and regulations;
Comptroller’s Handbook (c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectivesDecember 2016).
(2) As part of the audit program, the Board, or a committee thereof, shall ensure management develops a comprehensive annual risk assessment of all auditable areas of the Bank to ensure the scope, coverage, and frequency of audits are risk-based according to the Bank’s product lines, services, and operations and that audits provide sufficient oversight over the controls of the institution’s activities. The audit scope must be expanded to include all areas in which deficiencies were identified in the 2018 Report of Examination. Risk ratings shall be appropriately supported with consideration given to inherent risk and compensating internal controls. The Bank shall incorporate the annual risk assessment into its audit schedule.
(3) The Board, or a committee thereof, shall review and approve the audit scope and schedule at least annually. At least quarterly, the Audit Committee, shall review the status of the audit schedule to ensure all audits have been completed in a timely manner and that any deviation is documented and approved.
(4) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that or a committee thereof, which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and Board, or committee thereof, not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate prompt actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Compliance Agreement
Internal Audit. (1) Within ninety one hundred twenty days (90120) daysdays from the date of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) a. detect irregularities and weak practices in the Bank's operations;
(b) b. determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) c. assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
d. evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to ;
e. adequately cover all significant areas of the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas’s operations; and
(e) f. establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this ArticleArticle XIII.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted forwarded to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Bank shall implement and adhere to the internal audit program.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) daysdays of the date of this Agreement, the Board shall adopt, implement, develop and thereafter ensure Bank adherence approve a written program to an independent, improve the Bank’s internal audit function. The program sufficient shall include, but not be limited to:
(a) detect irregularities in reviewing the Bank's operationsinternal audit schedule and ensure all key areas of the bank and relevant regulations of the bank are included, including Regulations O and R;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish establishing an annual audit plan using a risk risk-based approach sufficient to achieve these audit objectives;
(c) reviewing and updating, as necessary, internal audit procedures to ensure they are sufficiently detailed and comprehensive to identify internal control deficiencies;
(d) evaluate the need for additional staffing;
(e) ensuring internal audit reviews the effectiveness of processes such as loan review to ensure they are appropriately identifying and reporting credit administration weaknesses, and that management addresses weaknesses in a timely manner;
(f) implementing descriptive identifiers for overall ratings assigned to an auditable area;
(g) implementing a system to track regulatory changes, and a procedure for disseminating information regarding regulatory changes to all affected bank personnel, including the Internal Auditor; and
(h) providing Regulation O and Regulation R training to the Internal Auditor and all other relevant officers and employees.
(2) As part of this the audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program written plan shall be promptly submitted forwarded to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Bank shall implement and adhere to the plan and the Board shall ensure Bank adherence to the plan.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) days, the The Board shall adopt, implement, and thereafter ensure Bank adherence to maintain an independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(cb) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(dc) ensure adequate audit coverage in all areas, including but not limited to sensitivity to market risk, investments, and compliance with Regulation Q, Regulation U, Regulation O, and the Bank Secrecy Act; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board audit committee shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed. In addition, the Board shall also relieve the internal auditors from all credit administration and compliance management functions currently performed by audit that are responsibilities of the lending and compliance departments.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, Board that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reportsreports and reports of examination, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) daysBy December 31, 2018, the Board Bank shall adoptrevise and after adoption by the Board, implement, and thereafter ensure Bank adherence to implement an independent, internal audit program sufficient to:
that is consistent with safe and sound standards for internal audit. Refer to (ai) detect irregularities the standards for Internal Audit Systems set forth in Section 11.B of the Interagency Guidelines Establishing Standards for Safety and Soundness, Appendix A to 12 C.F.R. Part 30; (ii) the guidance set forth in the Bank's operations;
“Interagency Policy Statement on the Internal Audit Function and Its Outsourcing” (bOCC Bulletin 2003-12); and (iii) determine Internal and External Audits booklet, M-AUD, of the Bank's level of compliance with all applicable laws, rules and regulations;
Comptroller’s Handbook (c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectivesDecember 2016).
(2) As part of the audit program, the Board, or a committee thereof, shall ensure management develops a comprehensive annual risk assessment of all auditable areas of the Bank to ensure the scope, coverage, and frequency of audits are risk-based according to the Bank’s product lines, services, and operations and that audits provide sufficient oversight over the controls of the institution’s activities. The audit scope must be expanded to include all areas in which deficiencies were identified in the 2018 Report of Examination. Risk ratings shall be appropriately supported with consideration given to inherent risk and compensating internal controls. The Bank shall incorporate the annual risk assessment into its audit schedule.
(3) The Board, or a committee thereof, shall review and approve the audit scope and schedule at least annually. At least quarterly, the Audit Committee, shall review the status of the audit schedule to ensure all audits have been completed in a timely manner and that any deviation is documented and approved.
(4) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that or a committee thereof, which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and Board, or committee thereof, not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate prompt actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Agreement Between Patriot Bank and the Comptroller of the Currency (Patriot National Bancorp Inc)
Internal Audit. (1) Within ninety forty-five (9045) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program program, with particular emphasis on the Bank’s lending function, sufficient to:
(a) detect irregularities in the Bank's operations, particularly in the lending area;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas;
(e) review the Bank’s operating control procedures, practices, and accountability standards to verify they ensure the books and records of the Bank are routinely validated and reconciled to the general ledger on a monthly basis; and
(ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectivesthat is commensurate with the scope of the Bank’s operations and the risk profile of the Bank.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) The Bank shall submit the engagement letter that outlines the scope of the internal audit to be conducted by outside third parties to the Assistant Deputy Comptroller for review. Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) validate the integrity of Call Report preparation procedures and accuracy of supporting data, beginning with the June 30, 2008 Call Report;
(f) evaluate the Bank’s adherence to internal controls;
(g) validate the accuracy of loan portfolio coding, subsequent to management's completion of their internal review of this data;
(h) ensure adequate issues raised by regulators or audit coverage in are adequately addressed;
(i) adequately cover all areas; and
(ej) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions. Audit reports should clearly indicate when a follow-up audit is needed to ensure corrective action was effective.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Compliance Agreement
Internal Audit. (1) Within ninety one hundred twenty (90120) daysdays of the date of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program in conformance with the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Internal Audit Function and its Outsourcing,” dated March 17, 2003 (OCC Bulletin 2003-12). The program shall cover all key risk areas of the Bank, and be sufficient to:
(a) detect irregularities in e nsure sample sizes correspond with the Bank's operationsrisk of each auditable area;
(b) determine ensure audit reports explicitly identify the Bank's level root cause of compliance with all applicable laws, rules and regulationsissues found;
(c) evaluate expand the Bank's adherence audit exceptions tracking report to established policies include all findings from the external audit firm (McGladrey and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards Xxxxxx) and problem loan identification and classificationconsultants;
(d) ensure adequate audit coverage in all areasestablish an Audit Committee Charter that outlines the Audit Committee’s purpose, objectives, organization, authority, and responsibilities; and
(e) establish an annual audit plan using a risk based approach sufficient expand documentation of Audit Committee meetings to achieve these objectivesaddress all topics discussed during the meeting.
(2) As part of this audit program, the Board or the Audit Committee shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed, and shall assess the performance of the department or outside firm at least annually.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions and tracking the timeliness and effectiveness of such actions.
(75) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners The OCC shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 6) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerComptroller for review and determination of no supervisory objection.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adoptreview, implementrevise, and thereafter ensure Bank adherence to an independent, a risk-based and independent internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to high-risk areas as well as accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in all areasdetermine whether regulatory reports contain “material misstatements”; and
(ef) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
(8) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to this Article and the programs developed pursuant to it.
Appears in 1 contract
Samples: Banking Compliance Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areas; and
(ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) 180 days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program and correct each deficiency cited in the February 26, 2001 Report of Examination or any subsequent Report of Examination. The Board shall implement an internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and standards, problem loan identification and classification, and Information Technology Systems internal controls;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit scope, frequency, and audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(5) The Board shall ensure internal auditors create an appropriate audit trail containing documents to support all procedures performed and conclusions documented in audit reports.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed. The Board shall prepare a written description of the duties and responsibilities of the internal auditor, including any nonaudit duties.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, Board that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit procedures, and reports shall be in writing. Work papers should be sufficiently detailed to provide a clear audit trail of work performed. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) daysOn or before April 30, 2016, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, policies and procedures to ensure that the Bank’s internal audit program sufficient tofunction operates in a safe and sound manner. These policies and procedures shall include, at a minimum:
(a) detect irregularities in development of a risk assessment process that accurately risk rates all auditable areas and correlates the Bank's operationslevel of risk assigned to frequency of audits;
(b) determine annual review of the risk assessment process adopted pursuant to Paragraph (1), Subparagraph (a) of this Article, to ensure that it remains appropriate given the size and complexity of the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate adoption of a plan to ensure proper oversight and management of the Bank's adherence audit process, including monitoring, reporting and following up on scheduled audits to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;ensure their timely completion; and
(d) adoption of a plan to ensure adequate management is held accountable for providing timely and appropriate responses to audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient findings, including identification of and response to achieve these objectivesthe root cause of deficiencies found and establishment of plans to correct such deficiencies.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party, including any individual who is a director.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners The OCC shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(7) On or before February 29, 2016, the Board shall adopt a plan to perform all delinquent audits, to include any audits recognized as delinquent in the XXX, in any subsequent Report of Examination, by the Bank, or in any list provided to management by the OCC during any examination.
(8) The Board shall ensure that senior management is assigned responsibility and held accountable (to include, at a minimum, consideration in periodic performance reviews and compensation) for ensuring adherence to the program adopted pursuant to this Article.
(9) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerComptroller for review and determination of no supervisory objection.
Appears in 1 contract
Samples: Banking Compliance Agreement
Internal Audit. (1) Within ninety thirty (9030) days, the Board shall adoptadopt changes to the Bank's internal audit program, implement, and the Bank shall implement and thereafter ensure Bank adherence to an independent, a revised independent internal audit program sufficient tothat is consistent with the Internal Audit Section of the Office of Thrift Supervision ("OTS") Handbook, Section 355(February 2002), the Standards for Internal Audit Systems at 12 C.F.R. Part 170, Appendix A, and any subsequent OCC guidance that includes at a minimum:
(a) detect irregularities in development and maintenance of a risk-based audit plan, covering both financial and non-financial areas of the Bank's operations, with risk assessments to support the frequency and scope of reviews for each area covered by the plan;
(b) determine well documented procedures and testing to support the scope of each audit that adequately address internal controls, systems and the Bank's level of compliance with all established policies and procedures, and applicable laws, rules regulations and regulationsregulatory guidance;
(c) evaluate an assessment of the Bank's adherence to established policies and effectiveness of policies, procedures, with particular emphasis directed controls, and management oversight relating to the Bank's adherence to its loan policies concerning underwriting standards accounting and problem loan identification and classificationfinancial reporting;
(d) ensure adequate audit coverage auditors with the knowledge, experience and skills (including in specialty areas such as Bank Secrecy Act/Anti-Money Laundering ("BSNAML") compliance and information technology and security), to detect weaknesses, irregularities and instances of noncompliance, and conclude on the overall effectiveness of the Bank’s internal controls, systems, policies, procedures and risk management practices in all areasareas covered by the audit plan; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectivesexception tracking reports that include all audit recommendations and regulatory findings, with identified timeframes for follow-up.
(2) As part of this The Audit Committee shall annually review and approve the audit program, plan to ensure that audit risk assessments prepared by management appropriately reflect any changes in the Board Bank's operating environment and continue to support a risk based plan.
(3) The Audit Committee shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board Audit Committee shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(75) The audit staff Audit Committee shall have access to any records necessary for the proper conduct keep minutes of its activities. National bank examiners meetings and shall have access report to all reports and work papers of the audit staff and any other parties working on its behalffull Board at least quarterly, or more frequently if warranted.
(8) 6) Upon adoptioncompletion, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerADC.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety thirty (9030) days, the Board shall adoptdevelop, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) ensure areas of concern noted in the XXX receive appropriate corrective action;
(c) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(cd) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(e) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(df) ensure adequate audit coverage review and provide an opinion regarding whether regulatory reports beginning with the quarter ending December 2009 contain “material misstatements” within thirty (30) days of filing; for purposes of this Article, “material misstatements” has the same meaning as the term is used in the SEC’s Staff Accounting Bulletin No. 99 on Materiality (“SAB 99”) and Staff Accounting Bulletin No. 108 (“SAB 108”).
(g) adequately cover all areas; and
(eh) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program covering all areas of the Bank, sufficient to:
(a) detect irregularities and weak practices in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules rules, and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, Bank and shall assess the impact on the Bank of any audit deficiencies cited in such reportsreports within sixty (60) days of receipt.
(3) The If the Bank employs a third party to conduct the audits pursuant to this Article, the Board shall ensure that the Bank has processesit selects, personnelcontracts, oversees, and control systems to ensure implementation of and adherence to documents the program developed pursuant to this Articlethird party relationship in a manner that is consistent with the Third Party Relationships (OCC Bulletin 2001-47).
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing and executing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party, including any director.
(65) All audit reports shall be in writing. .
(6) The Board shall ensure that immediate actions are undertaken management responds in writing to remedy all deficiencies cited in audit reports, reports and that auditors maintain a written record describing takes immediate action to remedy those actionsdeficiencies.
(7) The Board shall ensure corrective actions are formally tracked until the corrective actions are implemented and their effectiveness is verified.
(8) The audit staff shall have access to any records necessary for the proper to properly conduct of its activities. National bank examiners The OCC shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Compliance Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an improve its independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) identify and report on root cause of any deficiencies to ensure successful remediation
(e) ensure adequate audit coverage in all areas;
(f) ensure audit follow-up on any outstanding internally identified issues or prior regulatory or external findings; and
(eg) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any regulator or third party providing services to the Bank, and . The Board or Audit Committee shall assess the impact on the Bank of any audit deficiencies cited in such reports, obtain management’s response, and followup to ensure that audit deficiencies have been effective.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions. This record should include management’s response and timeframes for corrective action.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners Bank Examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's ’s operations;
(b) determine the Bank's ’s level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's ’s adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areas; and
(ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writingwriting and timely reported to the Board. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners Examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Compliance Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies classification; concerning underwriting standards and problem loan identification and classification;and
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) . The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 7) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerDirector for Special Supervision/Fraud.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety thirty (9030) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board Board, or the Audit Committee thereof, and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners Bank Examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerADC.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed. The Board shall appoint an audit manager if an outside firm is used.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program program, which includes coverage of bank information systems, sufficient to:
(a) detect irregularities in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areasareas based on risk; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the qualifications, experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage in adequately cover all areas;
(f) determine conclusions and ratings on the quality of the areas audited; and
(eg) establish an annual audit plan using a risk risk-based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board or its Audit Committee shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the BoardBoard or its Audit Committee, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be in writing and filed directly with the Board or its Audit Committee and not through any intervening party.
(65) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those the deficiency, the projected corrective action, and the status of the corrective action.
(6) The audit staff shall evaluate in writing the effectiveness of the corrective action and recommend additional corrective actions, as necessary.
(7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerDirector.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(b) detect irregularities in the Bank's operations;
(bc) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(cd) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;; and
(de) ensure adequate audit coverage in all areas; and
(e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure require that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(6) All audit reports shall be in writing. The Board shall ensure require that management take immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(7) The Board shall monitor management’s progress in correcting deficiencies cited in any audit report or loan review.
(8) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 9) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety (90) 90 days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(d) ensure adequate audit coverage in all areas; and
(e) adequately cover all areas.
(2) As part this audit program, the Board shall:
(a) establish an annual audit plan schedule using a risk based approach sufficient to achieve these objectives.the objectives outlined in this Article;
(2b) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, Bank and shall assess the impact on the Bank of any audit deficiencies cited in such reports.;
(3c) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.; and
(5d) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party.
(63) All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(74) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 5) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy Comptroller.
(6) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
Appears in 1 contract
Samples: Banking Agreement
Internal Audit. (1) Within ninety sixty (9060) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program sufficient to:
(a) detect irregularities and weak practices in the Bank's operations;
(b) determine the Bank's level of compliance with all applicable laws, rules and regulations;
(c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting;
(d) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification;
(de) ensure adequate audit coverage review and provide an opinion regarding whether regulatory reports beginning with the quarter ending June 30, 2006, contain “material misstatements” within thirty (30) days of filing; for purposes of this Article, “material misstatements” has the same meaning as the term is used in the SEC’s Staff Accounting Bulletin No. 99 on Materiality (“SAB 99”).
(f) adequately cover all areas; and
(eg) establish an annual audit plan using a risk based approach sufficient to achieve these objectives.
(2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed.
(54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Audit Committee of the Board and not through any intervening party.
(6) . All audit reports shall be in writing. The Board shall ensure that immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions.
(75) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf.
(8) 6) Upon adoption, a copy of the internal audit program shall be promptly submitted to the Assistant Deputy ComptrollerADC.
Appears in 1 contract
Samples: Banking Agreement
