2005-07-15
The Office of Financial Institutions issued Bulletin BL-02-2005 to clarify examiner expectations for reviewing executive expenses during institutional examinations. Institutions must maintain written policies or procedures that mandate original invoices, restrict personal charges on corporate credit cards under Regulation O, and designate specific approval authorities for officers and the CEO. Examiners will sample selected expenditures to verify compliance and documentation rather than auditing all payments, while internal audit results and subsequent Audit Committee corrective actions remain mandatory.