Answer:
On any federal compliance topic, use the examination procedures used by your primary federal regulatory agency as the starting point. Adjust them to reflect your bank's policies and product lines as well as any prior criticisms.
The examination procedures are as close as you can get to "generally accepted auditing standards" in the compliance area. If your regulatory agency sees that you follow their procedures, they will "test" to see how well you do it. If they develop confidence in your results, they will devote their resources to other issues.
First published on BankersOnline.com 11/04/02