Has anyone reviewed the proposed rule on annual audits in the federal Register 11/02/07 for 12 CFR Parts 308 and 363?

Any comments or concerns?

How will it affect internal audit?

No, haven't looked at this, but I will. You don't happen to have a quick link to this do you? Finding these things sometimes is a real pain.

Here it is:

http://www.fdic.gov/news/news/financial/2007/fil07096.html

It depends on whether the policy affects your bank (are you over $1 billion and not public?), and what work that would be required if so would be assigned to IA.

For the most part, this is just a conformance of FDIC rules with Sarbanes Oxley Rule 404. My guess is that there are very few banks over $500 million that don't have to comply with 404 already (or will have to this year), and virtually no banks over $1 billion that don't have to comply with 404. So, the effect of this may be positive in that it reduces confusion between bank regulator requirements and SEC requirements.

Actually, as a mutual holding company / savings bank my bank is not subject to 404, and as we are approaching one billion in assets, we will soon be affected by this change.

Yes, this is not an uncommon asset size for a non-public bank. ($1 billion ain't what it used to be!)

I guess I was just projecting what I typically see to everyone. Banks in my area of the country that haven't been gobbled up by the big boys are typically very old banks, 80 to 100 years, and therefore the original shares have split and also been distributed over and over again to heirs such that a good portion of even the medium sized banks have enough shareholders to be classified as public. I actually know of a $145 million bank that is an SEC filer.

Given that, and for all you banks out there that now have to comply with this, my condolences. It's not overly fun! But truthfully, in a lot of instances does strengthen the organization because you learn a lot about yourselves.