The federal bank and thrift
regulatory agencies are issuing this policy statement to improve the
coordination and communication between external auditors and examiners.
This policy statement provides guidelines regarding information that
should be provided by depository institutions to their external auditors
and meetings between external auditors and examiners in connection
with safety-and-soundness examinations.
Coordination of External Audits and Examinations In most cases, the federal bank and thrift
regulatory agencies provide institutions with advance notice of the
starting date(s) of full-scope or other examinations. When notified,
institutions are encouraged to promptly advise their external auditors
of the date(s) and scope of supervisory examinations in order to facilitate
the auditors’ planning and scheduling of audit work. The external
auditors may also advise the appropriate regulatory agency regarding
the planned dates for the auditing work on the institution’s premises
in order to facilitate coordination with the examiners.
Some institutions prefer that audit
work be completed at different times from examination work in order
to reduce demands upon their staff members and facilities. On the
other hand, some institutions prefer to have audit work and examination
work performed during similar periods in order to limit the impact
of these efforts on the institutions’ operations to certain times
during the year. By knowing in advance when examinations are planned,
institutions have the flexibility to work with their external auditors
to schedule audit work concurrent with examinations or at separate
times.
Other Information Provided
by the Institution Consistent with
prior practice, a depository institution should provide its external
auditors with a copy of certain reports and supervisory documents,
including—
- the most recent regulatory report of condition (i.e.,
call reports for banks, and thrift financial reports for savings institutions);
- the most recent examination report and pertinent correspondence
received from its regulator(s);
- any supervisory memorandum of understanding with the
institution that has been put into effect since the beginning of the
period covered by the audit;
- any written agreement between a federal or state banking
agency and the institution that has been put into effect since the
beginning of the period covered by the audit; and
- a report of—
-
External Auditor Attendance
at Meetings Between Management and Examiners Generally, the federal bank and thrift regulatory agencies
encourage auditors to attend examination exit conferences upon completion
of field work or other meetings between supervisory examiners and
an institution’s management or board of directors (or a committee
thereof) at which examination findings are discussed that are relevant
to the scope of the audit. When other conferences between examiners
and management are scheduled (i.e., that do not involve examination
findings that are relevant to the scope of the external auditor’s
work), the institution shall first obtain the approval of the appropriate
federal bank or thrift regulatory agency in order for the auditor
to attend the meetings. This policy does not preclude the federal
bank and thrift regulatory agencies from holding meetings with the
management of depository institutions without auditor attendance or
from requiring that the auditor attend only certain portions of the
meetings.
Depository institutions should ensure that their external
auditors are informed in a timely manner of scheduled exit conferences
and other relevant meetings with examiners and of the agencies’ policies
regarding auditor attendance at such meetings.
Meetings and Discussions Between External
Auditors and Examiners An auditor may
request a meeting with any or all of the appropriate federal bank
and thrift regulatory agencies that are involved in the supervision
of the institution or its holding company during, or after completion
of, examinations in order to inquire about supervisory matters relevant
to the institution under audit. External auditors should provide an
agenda in advance to the agencies that will attend these meetings.
The federal bank and thrift regulatory agencies will generally request
that management of the institution under audit be represented at the
meeting. In this regard, examiners generally will only discuss with
an auditor examination findings that have been presented to the depository
institution’s management.
In certain cases, external auditors may wish to discuss
with regulators matters relevant to the institution under audit at
meetings without the representation from the institution’s management.
External auditors may request such confidential meetings with any
or all of the federal bank and thrift regulatory agencies, and the
agencies may also request such meetings with the external auditor.
Confidentiality of Supervisory
Information While the policies of the
federal bank and thrift regulatory agencies permit external auditors
to have access to the previously mentioned information on depository
institutions under audit, institutions and their auditors are reminded
that information contained in examination reports, inspection reports,
and supervisory discussions—including any summaries or
quotations—is
confidential supervisory information and must not be disclosed to
any party without the written permission of the appropriate federal
or thrift regulatory agency. Unauthorized disclosure of confidential
supervisory information may subject the auditor to civil and criminal
actions and fines and other penalties.
Issued
jointly by the Board of Governors of the Federal Reserve System, the
Federal Deposit Insurance Corporation, the Office of the Comptroller
of the Currency, and the Office of Thrift Supervision, July 23, 1992
(SR-92-28).
