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Good afternoon. I have recently transferred to this credit union due to a merger. There are two of us, internal auditors.  All CU Directors (Management) meet the week before the BOD meeting to go over packet and to review to ensure no grammatical errors and so forth on the report before it goes to the BOD. The Audit Committee packet is also reviewed in this meeting. I was an external auditor for four years going from credit union to credit union. As I audited certain programs, deficiencies were obvious and have to be fixed.

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I have not been able to determine if there are any specific or special provisions out there relating to TDR/Modified Loans that deal with a member who has a loan (real estate or consumer loan), modified under SCRA, and subsequently experiences difficulty paying it and asks for help.  As an example, are there any special guidelines for HARPs or HAMPs that deal with this situation or will the loan always and only fall under SCRA?

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Do you require staff to retain purchase orders (for office supplies, etc) to compare to invoices? If so, who retains them? For how long?

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We are scheduled to have an 06-cu-10 IS& T audit. However, it appears as if we have not had a 748 Annual Review since 2007. I asked for a proposal from a third party. Management declined the 748 Risk Assessment. As I am not trained nor certified in this area, I was looking forward to a third party. What does your credit union do in regards to IT and the 748 Risk Assessment. I wanted to give management a scenario with the implications of future costs that this could cost. Thanks. Beronica

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On GFE's, in instances in which our CU errs on a fee (such as Title fee, or mortgage tax) in excess of a tolerance level , the CU absorbs the cost. It is then documented on the GFE as POC/L (Paid outside of closing by lender).  One of our closing attorneys has told our Mortage Officer she heard BOA was recently audited, and it was determined "POC/L" was not an acceptable method for such disclosure.  Thoughts?  How are you all disclosing such items? 

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Like many, if not most of you, we allow employees to have ODPs on their accounts.  Our ODP limit (for any member) is $800.  Question is, do you allow employees to have ODPs on multiple accounts to which they have access?

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Hi,We are updating our OFAC risk assessment.  I realize this assessment may share issues with the BSA/AML assessment.If you have an OFAC assessment you are willing to share, please email me at bmcmahon@cenfedcu.org.If you don't - can you tell me if you OFAC every official check/cashiers check you print?  If you don't, what is your dollar threshold, and how did you decide on that dollar amount.  Or does your system perform the OFAC testing so the teller/msr is not taking the time to do it themselves?Thank you!   

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Does anyone have an Anti-Predatory Lending Policy they would be willing to share?  An audit program would also be helpful.  Thank you.  

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Our CU has recently started an internal audit department.  I am in the process of developing an Internal Audit Policy and was wondering if anyone had a policy that they would be willing to send me to compare with.

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I am being asked to move from a space designed to allow for confidentiality to a space that is shared with another department.  I feel strongly that this will impact our efficiency and confidentiality as the audit team frequently discusses/brainstorms on audits and employee investigations.  Please share if you have a space designed for confidentiality or if you are in an open space. I need to get a feel for how others are situated.  Thanks! 

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