Compliance Documentation Gap Report
Prepared for FINRA Small Firm AML Template | April 02, 2026 | Generated by FinCompliance
0/100
Compliance Documentation Score
185
Warnings (should fix)
Detailed Findings
[ERROR] DocumentMetadata: Missing required metadata: 'Effective Date'. All compliance documents must include an effective date.
[ERROR] DocumentMetadata: Missing required metadata: 'Last Reviewed'. Examiners check that policies are reviewed regularly.
[ERROR] DocumentMetadata: Missing required metadata: 'Next Review Date'. Demonstrates commitment to ongoing review.
[ERROR] DocumentMetadata: Missing required metadata: 'Approved By'. Documents must show who authorized the policy.
[ERROR] DocumentStructure: Document missing top-level heading (# Title).
[ERROR] BSA_FivePillars: BSA/AML policy is missing required pillar: 'Designated BSA Compliance Officer'. FFIEC BSA/AML Examination Manual requires all five pillars. (FFIEC BSA/AML Manual, Core Overview)
[SUGGESTION] Line 35: Passive voice detected: 'will be reviewed'. Assign clear responsibility with active voice (who does what).
[WARNING] Line 35: Unquantified frequency: 'regular basis'. Specify exact cadence (daily/weekly/monthly/quarterly/annually).
[WARNING] Line 35: Unsupported assertion: 'controls are in place'. SOX controls must reference specific evidence (test results, screenshots, logs).
[WARNING] Line 45: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] Line 45: Use 'when [specific trigger condition]' instead of 'if necessary' for regulatory precision.
[SUGGESTION] Line 45: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[WARNING] Line 45: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] Line 59: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 59: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 59: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] Line 61: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 63: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 65: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 67: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 67: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 77: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 83: Weak commitment language: 'should consider'. Consider 'shall' or 'must' for mandatory requirements.
[WARNING] Line 85: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 85: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 85: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 93: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 93: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 93: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 93: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 95: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 111: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 111: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 111: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] Line 111: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 113: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 125: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 135: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 135: Unquantified frequency: 'regular basis'. Specify exact cadence (daily/weekly/monthly/quarterly/annually).
[WARNING] Line 137: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 137: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 181: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 181: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 185: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 189: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 207: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 207: Unspecified timeframe: 'within a reasonable period'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] Line 209: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 223: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 225: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 225: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 225: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 225: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 234: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 241: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 251: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 251: Unspecified timeframe: 'within a reasonable time'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] Line 251: Use 'within [X] business days' instead of 'reasonable time' for regulatory precision.
[WARNING] Line 251: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 253: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 253: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 261: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 269: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 269: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 269: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 269: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 269: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 269: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 275: Unspecified timeframe: 'within a reasonable period'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] Line 277: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 277: Unspecified timeframe: 'within a reasonable period'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] Line 277: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 279: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 291: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 291: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 297: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 327: Unspecified timeframe: 'within a reasonable time'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] Line 327: Use 'within [X] business days' instead of 'reasonable time' for regulatory precision.
[WARNING] Line 347: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 347: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 347: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 351: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 371: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 371: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 381: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] Line 385: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 407: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 429: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 429: Unassigned responsibility: 'employees will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 429: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 429: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 429: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 437: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 437: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 447: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 461: Use 'when [specific trigger condition]' instead of 'if necessary' for regulatory precision.
[WARNING] Line 463: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 463: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 463: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 493: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 495: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 507: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 507: Use 'at least [quarterly/monthly/annually]' instead of 'periodically' for regulatory precision.
[WARNING] Line 507: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 507: Use 'at least [quarterly/monthly/annually]' instead of 'periodically' for regulatory precision.
[WARNING] Line 527: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 535: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 535: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 537: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] Line 545: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] Line 555: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 573: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 573: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 575: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 575: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 577: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 577: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 579: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 581: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 581: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] Line 603: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 605: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 607: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 611: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 613: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 613: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 617: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 617: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 617: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 635: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] Line 635: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] Line 635: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] Line 635: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[WARNING] Line 637: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 637: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 647: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 647: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 647: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 664: Use 'at least [quarterly/monthly/annually]' instead of 'regularly' for regulatory precision.
[WARNING] Line 800: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 810: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] Line 812: Passive voice detected: 'will be reported'. Assign clear responsibility with active voice (who does what).
[WARNING] Line 812: Use 'at least [quarterly/monthly/annually]' instead of 'regularly' for regulatory precision.
[WARNING] Line 814: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 814: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 814: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 814: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] Line 816: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 816: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 818: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 818: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[ERROR] Line 826: Risky language in BSA/AML document: 'draft'. Examiners interpret this as non-compliance.
[WARNING] Line 828: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 828: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 828: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 838: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 838: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 838: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 848: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 848: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[ERROR] Line 856: Risky language in BSA/AML document: 'draft'. Examiners interpret this as non-compliance.
[ERROR] Line 866: Risky language in BSA/AML document: 'draft'. Examiners interpret this as non-compliance.
[WARNING] Line 866: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 880: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 898: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 902: Unassigned responsibility: 'We shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 910: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 910: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 910: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 912: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 912: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 912: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 912: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 912: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 924: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 924: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 932: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 932: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 932: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 932: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 932: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 942: Unassigned responsibility: 'We shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] Line 956: Passive voice detected: 'will be reviewed'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] Line 956: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[WARNING] Line 958: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 958: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 958: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 958: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 958: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 968: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 972: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 972: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 974: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] Line 974: Passive voice detected: 'will be updated'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] Line 992: Passive voice detected: 'will be performed'. Assign clear responsibility with active voice (who does what).
[WARNING] Line 992: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] Line 992: Passive voice detected: 'will be performed'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] Line 996: Passive voice detected: 'will be performed'. Assign clear responsibility with active voice (who does what).
[WARNING] Line 996: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] Line 996: Passive voice detected: 'will be performed'. Assign clear responsibility with active voice (who does what).
[WARNING] Line 1004: Unassigned responsibility: 'staff will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 1004: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 1004: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] Line 1012: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 1012: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] Line 1012: Passive voice detected: 'will be reviewed'. Assign clear responsibility with active voice (who does what).
[WARNING] Line 1020: Unassigned responsibility: 'Employees will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] Line 1020: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
What These Findings Mean
Each error represents a gap that NCUA or OCC examiners are likely to cite as a finding during your next examination. Errors include missing required policy elements, prohibited language suggesting incomplete compliance, and structural issues that prevent examiner review.
Warnings are issues that weaken your documentation but may not result in a formal finding. These include vague language, unspecified timeframes, and unassigned responsibilities that make policies harder to enforce and audit.
Recommended Next Steps
- Address all errors before your next examination cycle
- Review warnings with your compliance officer or committee
- Consider a full documentation suite review across all compliance policies
Want a full compliance documentation audit?
FinCompliance checks your entire policy suite against BSA/AML, SOX, PCI-DSS, GLBA, and NCUA requirements. Get a complete gap analysis with specific remediation steps.
Contact: bipinrimal314@gmail.com | github.com/BipinRimal314/comply