The key to complying with the new requirement at the $1 billion milestone is the early development of a roadmap that ensures a smooth adoption. The bank’s goal should be to have internal controls designed and operating effectively on the first day of the fiscal year in which this milestone applies. Board members and management that start late and identify modifications to the design and operation of internal controls midyear often find themselves facing resource constraints and related costs that could have been avoided. The roadmap is designed to assist banks and their audit committees by describing some best practices they can use in evaluating the status of their internal controls implementation. With the expiration of the FDICIA relief provided by the regulators, many banks will be subject to compliance with the requirements of one of these FDICIA thresholds in the upcoming years. A proactive approach with constant monitoring and communication between all parties is a must. To assist with the oversight, we recommend developing a roadmap with milestones to monitor and stay on track for a successful adoption. The following roadmap (figure 1) shows when the more significant requirements of the $1 billion threshold will first apply. Conclusion If you have any questions about the FDICIA implementation roadmap and related requirements, please contact us at www.plantemoran.com/contactus. The key to complying with the new requirement at the $1 billion milestone is the early development of a roadmap that ensures a smooth adoption. Figure 1 7 Colorado Banker
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