2016-06-09
The Oklahoma Superintendent of Banks mandates that banks maintain a written internal audit program approved by the Board of Directors to safeguard assets and reduce violations. The guidelines specify mandatory quarterly functions, such as reconciling accounts and verifying cash, alongside annual duties including policy reviews and verification of securities and loan participations. Compliance is achieved by meeting these minimum sampling and verification standards, although an unqualified external audit opinion from a CPA firm may serve as an acceptable alternative.
Minimum Audit Requirements A written internal audit program shall be approved by the Board of Directors. The program will define the scope of the audit, be reviewed on a periodic basis, and revised by the Board when necessary. The Board of Directors or an auditor selected by the Board should perform the actual audit. A comprehensive internal audit program should include, but may not be limited to: Quarterly Functions
Minimum Audit Requirements (Continued) 5) Review plans and policies established by the Board, including: the Loan Policy, the Investment Policy, the Funds Management Policy and Contingency Funding Plan, the Management Succession Plan, and the Strategic Plan, to ensure they address the institution’s current and planned business lines, activities, and risks. 6) For all Other Real Estate and Other Assets acquired since the previous audit ascertain: a. The Other Real Estate was properly recorded at the fair value less cost to sell; b. The Other Assets were properly recorded at the fair value; c. The expenses and income associated with the property are recorded to the proper bank expense and income accounts; and d. The property is carried in compliance with K.S.A. 9-1102. 7) Ascertain that loan losses and recoveries are properly recorded and that ledgers pertaining to charged off accounts are accurately maintained, pursuant to K.A.R. 17-11-19. 8) Verify the bank is maintaining proper audit trails by tracing a sampling of transactions. 9) Check to insure fidelity and casualty insurance are in force and that all policies have been reviewed and approved by the Board. 10) If the bank obtains an opinion audit by a CPA firm, the OSBC will accept their percentage sampling. In lieu of an opinion audit, direct verification of loan and deposit accounts will be, at a minimum, 5% of the actual number of loan accounts and 2.5% of the actual number of deposit accounts. The sampling should be random enough to include loan and deposit accounts of various sizes. Implementation of an audit program should locate differences in accounts, safeguard assets, and reduce violations. A record of each quarterly audit's results should be noted in the Board of Directors' minutes, per K.S.A. 9-1116(b), and working papers should be kept for Directors' and examiners' review. If the bank obtains an “unqualified” opinion audit by a CPA firm, the OSBC will accept the audit in lieu of the minimum guidelines. Any other type of audit opinion would have to meet the minimum guidelines. OSBC 4/2016 2