Automation Tips From Andy

Problem: You have completed all the audit workpapers and drawn your basic conclusions. How do you quickly, and with minimal effort, put all of this in a meaningful report that will be brief enough for management's review and informative to the persons who have to correct the violations?

Solution: In your word processor, compose a common report form and save it as a template. Have this written with headings already placed and as few blanks as possible. In other words, make as much as you can a part of the template so that you do not have to re-enter it. Make use of your headers and footers so that you do not have keep typing in document titles and page numbers.

The Date of the report can be a "field" your software program will automatically update for you. There are several ways to do this. First, you could use a Print-Date (which inserts the date and time that a document was last printed). And there is my preferred method: the Saved-Date (which inserts the date and time a document was last saved). You can also do this with page numbers so you do not have to keep up with constant changes, and with the document's name and location within your file structure.

To add proper citations in the report, build a source document from which you will cut and paste into the audit report. I created a document called "Boilerplate Violations" and put violations in citation-numerical order. Over time, this will become quite a detailed list.

Example: After auditing adverse action notices in an ECOA audit, I noticed some incorrect reasons on the notice. I opened my report template and started filling it out. I wanted to cite the violation so I opened my violations source document and copied and pasted the following into my report:
"Reg. B ?202.9(a)(2)(i) - Requires that the specific reasons must relate to and accurately describe the factors actually considered by a creditor."

You can follow any compliance lingo with a plain English description of what was done and a list of accounts affected.

Note that I have my citations underlined. This makes them easy to find on the audit report. It is also good to double-underline any problems requiring corrective action. Again, they are easy for the users to read and find. The audit calendar (see Vol. 3, #3) will have a lot of cells to the right if done in a spreadsheet. Those cells can be used to hold these corrective actions suspense dates in an unprinted area (if you choose). Each time you review your calendar, you can scroll right and see if corrective actions were required and actually done.

Andy Zavoina, CRCM, Senior Vice President and Compliance Officer, First National Bank, Killeen and Fort Hood National Bank, Fort Hood, Texas. Both banks are part of First Community BancShares, Inc.

Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 9, 7/98