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Willful Violations of Opening Procedures

11/05/2001

I was researching information on BOL and came across an answer that you had given regarding Opening Procedures - one vs. two employees. We currently have a policy in place that requires two persons to open. The problem...our CFO arrives extremely early and opens by herself. She knows the policy and accepts responsibility for the fact that she is not following it. The other problem....during a recent audit we were cited for this. The auditors arrive early and thus saw her disregarding policy. I know in Banking that senior management always presents this problem but I need to address it. I really don't want to change our two person policy. The auditors recommended having each employee sign an acknowledgment of policy to be placed in their file. Do you have any other suggestions? We are a very small 2 branch organization in the country.

Combining Auditor & Security Roles

11/01/2001

Question: In several of your workshops, I've heard you and other speakers advise against combining the roles of Auditor and Security Officer, especially when the Security Officer

Branch Signage Display Requirements

10/01/2001

Under what Act or Regulation is it specified that each branch a "Notice of Availability of Financial and Other Information" must be displayed?

Privacy & Monitoring Service Providers

08/06/2001

How do banks intend to monitor their service providers to confirm that they are maintaining appropriate security measures to safeguard the bank's customer information? We are looking for a practical, reasonable way to do this.

Marketing "Don'ts"

02/05/2001

Do you have any "Never do this!" type items for bank marketers? I have been in marketing at other companies, but this is my first time at a bank and I'm wondering if there are some types of campaigns that just don't work well.

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Who should conduct the investigation?

02/27/2022

We have an internal fraud in our financial institution? Internal Audit, Human Resources and the Security Department are in a major fight over who should be handling the investigation! My question is who should be conducting the investigation?

The Auditors may not be able to help you!

02/20/2022

We are conducting an internal fraud examination concerning three people who might have done it. Our CEO has contacted our outside auditing firm for help. I don’t think the person they sent has even handled an internal fraud case before. What should we do?

Joint Acct-1 Spouse Conducting Suspicious Activity

01/23/2022

I have a BSA question about a Suspicious Activity Report. It is a joint account with a husband and wife, but the husband is solely the one conducting the suspicious activity. We have had no interaction with the wife and have no suspicion of her -- she is a non-player in the event. When we file the SAR, how do we treat the wife? Is she a subject by default? She's not a victim. Do we leave her off entirely?

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