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Too often, we are under pressure to develop a quick policy, and we find ourselves creating a complex document that, at the very least creates additional burden, impractical and impossible tasks and a monitoring nightmare.Read Full
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Oversight of the internal audit function is a responsibility of the board of directors and senior management and cannot be delegated. Effective oversight helps to ensure that the internal audit function addresses the risks posed by the nature and complexity of current and planned activities. By following the interagency guidance and keeping tabs on several key administrative areas, directors and senior management can help ensure a strong internal audit foundation. The internal audit function, whether internal or outsourced to a third party provider, can be considered as an expense, however, when the possibility of fraud prevention is included in the mix, most directors and management can appreciate the internal audit function.Read Full
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How does Bank senior management know and understand what examiners are looking for, and how do they meet the regulator’s needs while doing what is best for the Bank?Read Full
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With the extensive accumulated knowledge contained in the Federal Financial Institution Examination Council (“FFIEC”) Bank Secrecy Act / Anti-Money Laundering Manual (“Manual”) (and its recent updates), why is it that we are still seeing a number of Cease and Desist Orders (C&D), and record breaking Civil Monetary Penalties related to BSA / AML?Read Full
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The FDIC is ready to start insuring new charters.
In an interview last month, FDIC Chairman Sheila Bair conceded that the agency had let too many new banks open with business plans dependent on commercial real estate lending, or brokered deposits.Read Full
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In 2011, community banks will revisit many of the troubled loans restructured in the past year.
Among institutions with less than $20 billion of assets, troubled debt restructurings rose 64% as of September 30 (compared to a year earlier). More than a third of such loans fell back into delinquency, making it difficult to determine whether more restructuring will fix the problem or extend the misery.Read Full
Director of Internal Audit
Philip Gonzalez, Director, has over 40 years of experience in the financial services industry, holding a wide variety of executive and senior management experience at community banks and financial institutions.