Internal Control Questionnaires and Verification Procedures

Policies for Domestic and Foreign Due From Bank Demand Deposits

1. Has the board of directors, consistent with its duties and responsibilities, adopted written policies for due from bank accounts that:

   1. Provide for periodic review and approval of balances maintained in each such account?

   2. Indicate person(s) responsible for monitoring balances and the application of approved procedures?

   3. Establish levels of check-signing authority?

   4. Indicate officers responsible for approval of transfers between correspondent banks and procedure for documenting such approval?

   5. Indicate the supervisor responsible for regular review of reconciliations and reconciling items?

   6. Indicate that all entries to the accounts are to be approved by an officer or appropriate supervisor and that such approval will be documented?

   7. Establish time guidelines for charge-off of old open items?

   8. Establish procedures for entering into revocable reserve account charge agreements?

2. Are the policies for due from bank accounts reviewed at least annually by the board to determine their adequacy in light of changing conditions?

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