I was just informed by our outside audit group that banks that have too many exception error's will receive an automatic MOU. It was stated that the exams are tougher right now, and that it's mandated that the field examiners do this automatically. We are regulated by FDIC - does anyone have any thoughts on this they would like to share?

Unfortunately, the OCC has said something worse. They've informed us that their regulations require (no leeway) them to issue a cease and desist if they note a repeat violation of law from one exam to the next. That's scary! Unfortunately, I think that's the environment we live in these days!

See Section 8(s) of the FDI Act. This states that examiners shall (not may) issue a cease and desist order if they discover a bank has not:
1. established a BSA program, or
2. corrected a previous BSA violation.

The agencies have excused themselves from following this Congressional mandate for years. All that's happening now is that they are beginning to do what the law requires.