Answer:
Although the examination process was theoretically “homogenized” by publication of the FFIEC manual in 2005, there are still significant differences between the agencies and even specific examination teams within those agencies. It’s accurate to say that regulators claim to be doing a more “risk-based” analysis and that they are relying more heavily on the bank’s own independent examination to ferret out specific problems. While regulators cannot mandate “early” compliance with the new CDD regulation, they can certainly take the measure of a bank’s efforts to date during their near term examinations.
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