Supplemental Policy Statement on the Internal Audit Function and Its Outsourcing

The Board of Governors of the Federal Reserve System issued this supplemental guidance to enhance the 2003 interagency standards regarding the internal audit function and its outsourcing for institutions with over $10 billion in assets. The document outlines requirements for governance, operational effectiveness, and independence, while clarifying restrictions on external auditor services following changes to the FDI Act. It further details supervisory expectations for board oversight of outsourcing arrangements and examiner reliance on internal audit work.

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SR 13-1 / CA 13-1: Supplemental Policy Statement on the Internal Audit Function and Its Outsourcing

BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D.C. 20551

DIVISION OF BANKING SUPERVISION AND REGULATION

DIVISION OF CONSUMER AND COMMUNITY AFFAIRS

SR 13-1 / CA 13-1

January 23, 2013

Revised October 1, 2025

Attachment Reposted October 1, 2025

On October 1, 2025: This letter’s attachment, Supplemental Policy Statement on the Internal Audit Function and Its Outsourcing , was revised to remove references to reputational risk.

TO THE OFFICER IN CHARGE OF SUPERVISION AT EACH FEDERAL RESERVE BANK

SUBJECT:

Supplemental Policy Statement on the Internal Audit Function and Its Outsourcing

Applicability to Community Banking Organizations: This guidance does not apply to community banking organizations, defined as institutions supervised by the Federal Reserve with total consolidated assets of $10 billion or less. 1

The Federal Reserve is issuing the attached policy statement, Supplemental Policy Statement on the Internal Audit Function and Its Outsourcing, to provide institutions 2 with additional guidance related to interagency guidance that was issued in 2003 and remains in effect. 3 Building upon the 2003 interagency guidance, the attached supplemental guidance addresses characteristics, governance, and operational effectiveness of an institution’s internal audit function.

Further, this supplemental guidance explains changes over the past several years in banking regulations related to auditor independence and limitations placed on the external auditor. In summary, the supplemental guidance addresses:

Enhanced Internal Audit Practices – discusses the enhancements that an institution should incorporate into its internal audit function to address lessons learned from the recent financial crisis.

Internal Audit Function – addresses the characteristics, governance, and operational effectiveness of an institution’s internal audit function.

Internal Audit Outsourcing Arrangements – covers the responsibilities of an institution's board of directors and senior management to provide appropriate oversight of internal audit outsourcing arrangements.

Independence Guidance for the Independent Public Accountant – addresses certain changes to Section 36 of the FDI Act 4 enacted since the issuance of the 2003 interagency guidance. Further, the supplemental guidance discusses the restrictions on the services of an institution’s external auditor.

Examination Guidance – discusses the supervisory assessment of an institution’s internal audit function and the ability of examiners to rely on work performed by internal audit.

Reserve Banks are asked to distribute this supplemental guidance to supervised institutions with greater than $10 billion in total consolidated assets, including state member banks, domestic bank and savings and loan holding companies, and U.S. operations of foreign banking organizations, as well as to their supervisory and examination staff, as appropriate. Questions on the attached guidance should be addressed to Steven P. Merriett, Deputy Associate Director and Chief Accountant-Supervision, at (202) 452-2531; or Terrill L. Garrison, Jr., Senior Accounting Policy Analyst, at (202) 452-2712; or Phyllis L. Harwell, Assistant Director, Consumer Compliance, at (202) 452-3658. In addition, questions may be sent via the Board’s public website. 5

signed by Michael S. Gibson Director Division of Banking Supervision and Regulation

signed by Sandra F. Braunstein Director Division of Consumer and Community Affairs

Attachments:

Supplemental Policy Statement on the Internal Audit Function and Its Outsourcing

(PDF)

Cross References:

SR letter 12-17 / CA letter 12-14 , “Consolidated Supervision Framework for Large Financial Institutions.”

SR letter 03-5 , “Amended Interagency Guidance on the Internal Audit Function and its Outsourcing”

Notes:

Section 4 of the attached policy statement, however, clarifies certain changes to the Federal Deposit Insurance Corporation regulation (12 CFR part 363) on independence standards for independent public accountants at insured depository institutions with total assets of $500 million or more, which were adopted pursuant to 2009 amendments to Section 36 of the Federal Deposit Insurance Act (FDI Act). Return to text

For purposes of this guidance, "institutions" refer to state member banks, domestic bank and savings and loan holding companies, and U.S. operations of foreign banking organizations with total consolidated assets of $10 billion or more. Return to text

Refer to SR letter 03-5, "Amended Interagency Guidance on the Internal Audit Function and its Outsourcing." Return to text

See 12 CFR part 363. Return to text

See http://www.federalreserve.gov/apps/contactus/feedback.aspx . Return to text

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Last Update: October 01, 2025