“Documentation” or more specifically, the lack thereof, hasaccounted for nearly all the IT examination findings I've seen inthe past year to year and a half in community financialinstitutions.

In other words, the financial institution's policies andprocedures were satisfactory, but their documentation todemonstrate that actual practices followed policy and procedure waseither non-existent or insufficient.

Written polices begin the process, which must always haveregulatory guidance as their target. Policies should trackguidance precisely; if guidance states that you should or must dosomething, your policies should state that you do, or you will.

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