Common use of AUDIT PROGRAM Clause in Contracts

AUDIT PROGRAM. (1) The Board shall immediately implement and thereafter ensure Bank adherence to an independent, internal audit program developed in compliance with the MOU. This program must be sufficient to: (a) detect irregularities in the Bank's operations; (b) determine the Bank's level of compliance with all applicable laws, rules and regulations; (c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification; (d) ensure adequate audit coverage in all areas; including a review of internal control systems; and (e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives. (2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article. (4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed. (5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party. (6) All audit reports shall be in writing. The Board shall ensure that timely actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions. (7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf. (8) If any changes are subsequently made to the audit program, a copy of the revised program shall be promptly submitted to the Assistant Deputy Comptroller.

AUDIT PROGRAM. (1) The Within ninety (90) days of this Agreement, the Board shall immediately implement prepare and thereafter ensure Bank adherence submit to an independent, internal the Assistant Deputy Comptroller for a prior written determination of no supervisory objection a revised audit program developed in compliance with the MOU. This program must be sufficient tothat: (a) detect irregularities includes procedures to assist in the Bank's operationscompleting operations audits; (b) determine detects irregularities and weak practices in the Bank's ’s operations; (c) determines the Bank’s level of compliance with all applicable laws, rules and regulations; (cd) evaluate assesses and reports the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting; (e) evaluates the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification; (df) ensure adequate establishes a line of communication for audit coverage in all areas; including reporting issues between the internal auditor, external auditors, audit committee, and board of directors; (g) ensures audit workpapers and documentation of conclusions provide a review of internal control systemsmeaningful audit trail and validation for findings and recommendations; (h) ensures timely management responses and corrective actions on identified weaknesses; and (ei) establish establishes an annual audit plan using a risk risk-based approach sufficient to achieve these objectives. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development of an audit policy and the performance of a Bank-wide risk assessment to guide the Bank’s development of the audit scope and annual coverage. The Board must ensure that higher risk areas are reviewed more frequently than lower risk areas. (3) As part of the audit program required by this audit programArticle, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article. (4) The Board shall ensure that the audit function program is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed. (5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and/or Board Audit Committee (comprised of at least two external directors) and not through any intervening party. (6) All audit reports shall be in writing. The Board shall ensure that timely actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain Upon receiving a written record describing those actions. (7) The audit staff shall have access to any records necessary for the proper conduct determination of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf. (8) If any changes are subsequently made to the audit program, a copy of the revised program shall be promptly submitted to no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the Bank’s revised audit program.

AUDIT PROGRAM. (1) The Within sixty (60) days, the Board shall immediately implement adopt, implement, and thereafter ensure Bank adherence to an independent, internal audit program developed in compliance with the MOU. This program must be sufficient to: (a) detect irregularities and weak practices in the Bank's ’s operations; (b) determine the Bank's ’s level of compliance with all applicable laws, rules and regulations; (c) assess and report the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting; (d) evaluate the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's ’s adherence to its loan policies concerning underwriting standards and problem loan identification and classification; (de) ensure adequate audit coverage in adequately cover all areas; including a review of internal control systemsareas (including, but not limited to consumer compliance and information technology); and (ef) establish an annual audit plan using a risk based approach sufficient to achieve these objectives. (2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reportsand implement a tracking process to follow-up on corrective actions. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article. (4) The Board shall ensure that the audit function is supported by an adequately trained and staffed internal department or outside firm, with respect to both the experience level and number of the individuals employed. (54) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party. (65) All audit reports shall be in writing. The Board shall ensure that timely immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions. (76) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf. (8) If any changes are subsequently made to the audit program7) Upon adoption, a copy of the revised internal audit program shall be promptly submitted to the Assistant Deputy Comptroller. (8) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.

AUDIT PROGRAM. (1) The Within sixty (60) days of this Agreement, the Board shall immediately implement prepare and thereafter ensure Bank adherence to an independentsubmit for a prior written determination of no supervisory objection, internal a revised audit program developed in compliance with the MOU. This program must be sufficient tothat: (a) detect irregularities includes procedures to assist in the Bank's operationscompleting operations audits; (b) determine detects irregularities and weak practices in the Bank's ’s operations; (c) determines the Bank’s level of compliance with all applicable laws, rules and regulations; (cd) evaluate assesses and reports the effectiveness of policies, procedures, controls, and management oversight relating to accounting and financial reporting; (e) evaluates the Bank's ’s adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification; (df) ensure adequate establishes a line of communication for audit coverage in all areas; including reporting issues between the internal auditor, external auditors, audit committee, and board of directors; (g) ensures audit workpapers and documentation of conclusions provide a review of internal control systemsmeaningful audit trail and validation for findings and recommendations; (h) ensures timely management responses and corrective actions on identified weaknesses; and (ei) establish establishes an annual audit plan using a risk risk-based approach sufficient to achieve these objectives. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development of an audit policy and the performance of a Bank-wide risk assessment to guide the Bank’s development of the audit scope and annual coverage. (3) As part of the audit program required by this audit programArticle, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article. (4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed. (5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and/or Board Audit Committee (comprised of at least two external directors) and not through any intervening party. (6) All audit reports shall be in writing. The Board shall ensure that timely actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain Upon receiving a written record describing those actions. (7) The audit staff shall have access to any records necessary for the proper conduct determination of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf. (8) If any changes are subsequently made to the audit program, a copy of the revised program shall be promptly submitted to no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the Bank’s revised audit program.

AUDIT PROGRAM. (1) The Within ninety (90) days, the Board shall immediately implement adopt, implement, and thereafter ensure Bank adherence to an independent, internal independent audit program developed in compliance with the MOU. This program must be sufficient to: (a) detect irregularities in the Bank's operations; (b) determine the Bank's level of compliance with all applicable laws, rules and regulations; (c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and problem loan identification and classification; (d) ensure adequate audit coverage in all areas; including a review of internal control systems; and, (e) establish an annual audit plan using a risk based approach sufficient to achieve these objectives. (2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article. (4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed. (5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party. (6) All audit reports shall be in writing. The Board shall ensure that timely immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions. (7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf. (8) If any changes are subsequently made to the audit programUpon adoption, a copy of the revised audit program shall be promptly submitted to the Assistant Deputy Comptroller.

AUDIT PROGRAM. (1) The By July 31, 2002, the Board shall immediately implement adopt, implement, and thereafter ensure Bank adherence to an independent, internal independent audit program developed in compliance with the MOU. This program must be sufficient to: (a) detect irregularities in the Bank's operations; (b) determine the Bank's level of compliance with all applicable laws, rules and regulations; (c) evaluate the Bank's adherence to established policies policies, procedures and proceduresregulatory reporting requirements, with particular emphasis directed to the Bank's adherence to its loan policies concerning underwriting standards and standards, problem loan identification and classification, loan payment extensions and deferrals, nonaccrual loans, repossessed assets, and the Allowance for Loan and Lease Losses; (db) ensure adequate audit coverage in all areas; including a review of internal control systems; and (ec) establish an annual audit plan using a risk based approach sufficient to achieve these objectives. (2) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports. The evaluations and assessments referred to in this paragraph shall be in writing and noted in the minutes of the Board. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article. (4) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of the individuals employed. (5) The Board shall ensure that the audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, that shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party. (6) All audit reports shall be in writing. The Board shall ensure that timely immediate actions are undertaken to remedy deficiencies cited in audit reports, and that auditors maintain a written record describing those actions. (7) The audit staff shall have access to any records necessary for the proper conduct of its activities. National bank examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf. (8) If any changes are subsequently made to the audit programUpon adoption, a copy of the revised audit program shall be promptly submitted to the Assistant Deputy Comptroller.