Keeping abreast of regulatory compliance issues can be a daunting task. Compliance covers all areas of your institution’s operations and the regulations are constantly changing. In order to ensure ongoing compliance with critical regulations, a regular review and assessment is a must.
Nearman, Maynard, Vallez, CPAs offers a wide range of compliance services, some of which are described below. To proceed in an organized manner, and given your staff’s time restraints, we have found it is sometimes easier to break down compliance into smaller areas. Doing so gives your staff time to develop a plan to correct any deficiencies found, in addition to doing their “regular” jobs, before moving on to the next compliance area.
Bank Secrecy Act Review
Bank Secrecy Act compliance continues to be at the forefront of the financial services industry. Both federal and state examiners have increased scrutiny of your bank secrecy compliance programs. Examiner emphasis remains on identifying risk, monitoring programs, and training for both employees and officials of your organization. In addition, focus is on ensuring you have an independent review of your bank secrecy compliance program.
The Federal Financial Institutions Examination Council (FFIEC) published an examination manual to provide guidance to examiners for carrying out Bank Secrecy Act (BSA) and Office of Foreign Assets Control (OFAC) examinations. The manual contains an overview of BSA compliance program requirements, BSA risks and risk management expectations, industry sound practices, and examination procedures. We use the guidance provided in the FFIEC’s examination manual, and subsequent information, as applicable to your institution to help ensure you receive a comprehensive, independent review that will meet regulatory requirements.
The National Automated Clearing House Association (NACHA) requires any financial institution that originates or receives ACH transactions to have an annual ACH review performed by December 1st of each year.
We perform specific procedures in accordance with Appendix 8, "Rule Compliance Audit Requirements" of the ACH Rules. In addition, we review other areas pertaining to ACH operations, including, but not limited to, a review of specific administrative controls, internal operating controls points, and a quality assurance program. The audit programs we use are structured to examine your institution’s compliance with NACHA requirements!