Internal Control Questionnaires and Verification Procedures

Internal Control Questionnaire

1. Do requests for all regulatory reports come to one individual or department?

2. Does that individual or department have the authority to request that the applicable banking department prepare required information?

3. To insure that all regulatory reports are submitted on a timely basis and are accurate, determine:

   1. If completion of the report requires information from several departments:

      • Is a written memorandum sent to the various departments requesting the information?

      • Is the memorandum addressed to a department head?

      • Does the memorandum have a due date?

      • Are procedures in effect to send second requests if the memorandum is not returned by its original due date?

      • Does completion of the memorandum require two signatures: that of the person gathering the information and that of the person’s superior who is held responsible for its accuracy?

   2. If completion of the report requires information from one department, is there separation of duties to insure that the raw data to complete the report is compiled by one person, and verified by another person, prior to submission?

4. After the report is prepared, but prior to its submission, is it checked by:

   1. The supervisor of the department preparing the report, who takes personal responsibility for its accuracy and submission on a timely basis?

   2. Bank personnel who have no part in the report’s preparation?

5. Do report working papers leave a clear audit trail from the raw data to the finished report, and are they readily available for inspection?

Previous: Regulatory Reports Next: Compliance with the reporting and inquiry requirements of the lost and stolen securities provisions of 17 CFR 240.17f-1.