Pub. 1 2013 Issue 2

spring 2013 15 audit function. Performing such activities is presumed to impair audit objectivity. The greatest risk of violating the inde- pendence principle comes frommixing consulting with auditing. The “gray area” between auditing and consulting offers opportunities for ob- servers (more specifically, regulators) to conclude that auditors have violated the independence principle when they write policies and procedures to be implement- ed in the banks in which they perform audit functions. For the most part, auditors and regulatory agencies believe that performing consult- ing services carries a relatively high risk of jeopardizing independence. Senior management needs to establish criteria to differentiate auditing and consult- ing work. The bank should appreciate and expect the auditors to protect the indepen- dence and objectivity of the audit function and not expect or allow the auditor (internal or external) to participate in any activity that would jeopardize the independence. Considering the strict standards required of the audit function and the regulatory view of independence, the board should ensure the audit function is clearly separate from the management function of policy making and the writing of procedures. Remember, auditors make recommendations for “Best Practices” to include in a policy, but should in no way be involved in the actual writing or implementation of the policy. Many banks are falling into the trap of using auditors to write critical documents as a result of a lack of resources, such as time to find the documents elsewhere or the cost of purchasing each policy. Compliance Alliance is ideal for Compliance Officers looking to be more efficient and to save their banks money. Banks using Compli- ance Alliance are currently saving a half to one full FTE. Compliance Alliance was developed to assist banks in navigating the expansion of compliance rules and regulations. Compli- ance Alliance currently provides more than 450 products, including calculators, cheat sheets, check lists, cliff notes, enforcement actions, flowcharts, forms, handouts, matri- ces, policies, procedures, risk assessments, training tools, webinars and worksheets, with new documents uploaded daily. The wide variety of resources allows each individual bank, no matter the size or the amount of time in business, to customize a group of documents specific to their needs. If there is ever a document that is needed but not available on the website, Compli- ance Alliance will create the document. The products on the Compliance Alliance website are produced in-house, allowing questions to be answered by the creator. The Compliance Hotline is available to answer your questions by phone, email and live chat with no limit to the number of questions or the amount of time spent speaking to an Attorney or Specialist. Each dedicated staff member at Compliance Al- liance has banking, regulatory and/or legal experience, giving them the knowledge to answer your questions but also empathy in understanding what your bank is facing. In addition to products, Compliance Alliance also offers many services to its subscribing banks. To help bankers with advertising reviews, Compliance Alliance offers a review checklist. If the bank’s Com- pliance Officer is not comfortable or lacks the time to complete the review, a Compli- ance Specialist fromCompliance Alliance can also complete the bank’s advertis- ing review for them. A few of the many other services include a compliance calendar, daily emails with news and links to the recently posted website docu- ments, weekly and monthly newsletters and links to all of the handbooks, manuals and regulatory guidance documents from the regulatory agencies. Another unique aspect is the All-Inclusive Guarantee: Compliance Alliance guar- antees that once you have made your subscription payment you will never be asked for another dime for any existing or future products. Compliance Alliance is also unique in that member banks are allowed an unlimited amount of usernames and passwords for the interactive website, allowing anyone in the bank to use the products and services. Compliance Alliance has built a regula- tory compliance team, consisting of eight veteran employees with regulatory and compliance experience, all of whom are well qualified to assist banks in address- ing the challenges of the rapidly changing regulatory environment. Compliance Alliance understands the challenges Compliance Officers are facing to find the correct resources for their banks. Each document is created to assist any bank, from the smallest to the largest. If your Internal Auditor is creating your poli- cies, don’t take the chance that your audits will not be considered independent. Call Compliance Alliance today! For more information about Compliance Alliance or to sign up for a free preview of the products and services, call 888- 353-3933. n Compliance Alliance Compliance Alliance is ideal for bankers who want easy-to-find, up-to-date compliance information. Here are some of the components of its services: • Cliff Notes on New Regulations (executive summaries) • Policy Templates • Procedures • Action Plans • Lending Matrices • Compliance Hotline • Checklists • Compliance Calendar • Risk Assessment Tools • Tracking Tools • Review of Advertising and Marketing • And much more!

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