Compliance Documentation Gap Report

Prepared for FINRA Small Firm AML Template | April 02, 2026 | Generated by FinCompliance

0/100
Compliance Documentation Score
12
Errors (must fix)
236
Warnings (should fix)
14
Suggestions

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 Manual, Core Overview)
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be reviewed'. Assign clear responsibility with active voice (who does what).
[WARNING] UnquantifiedFrequency: Unquantified frequency: 'regular basis'. Specify exact cadence (daily/weekly/monthly/quarterly/annually).
[WARNING] SOX_EvidenceRequirements: Unsupported assertion: 'controls are in place'. SOX controls must reference specific evidence (test results, screenshots, logs).
[WARNING] ProhibitedTerms: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] ProhibitedTerms: Use 'when [specific trigger condition]' instead of 'if necessary' for regulatory precision.
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[WARNING] ProhibitedTerms: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] ProhibitedTerms: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] WeakCommitmentLanguage: Weak commitment language: 'should consider'. Consider 'shall' or 'must' for mandatory requirements.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] ProhibitedTerms: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnquantifiedFrequency: Unquantified frequency: 'regular basis'. Specify exact cadence (daily/weekly/monthly/quarterly/annually).
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnspecifiedTimeframes: Unspecified timeframe: 'within a reasonable period'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[ERROR] UDAAP_DeceptiveLanguage: UDAAP risk: 'may vary'. CFPB flags imprecise conditional language that obscures costs or terms. Provide exact figures and conditions.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnspecifiedTimeframes: Unspecified timeframe: 'within a reasonable time'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] ProhibitedTerms: Use 'within [X] business days' instead of 'reasonable time' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnspecifiedTimeframes: Unspecified timeframe: 'within a reasonable period'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnspecifiedTimeframes: Unspecified timeframe: 'within a reasonable period'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnspecifiedTimeframes: Unspecified timeframe: 'within a reasonable time'. State exact days/hours (e.g., 'within 30 calendar days').
[WARNING] ProhibitedTerms: Use 'within [X] business days' instead of 'reasonable time' for regulatory precision.
[ERROR] BSA_CIPWeakLanguage: CIP weak language: 'should obtain'. CIP requirements are mandatory. Use 'must collect' or 'shall collect' — not aspirational language.
[WARNING] UDAAP_BuriedDisclosures: UDAAP buried disclosure risk: 'including without limitation'. CFPB targets language that interferes with consumer comprehension. Simplify.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] ProhibitedTerms: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'Foreign Shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'Foreign Shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'foreign shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'foreign shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'Foreign shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'foreign shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'Foreign shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'foreign shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'foreign shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'employees will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'foreign shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'foreign shell'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'shell bank'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'shell bank'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'shell bank'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] ProhibitedTerms: Use 'when [specific trigger condition]' instead of 'if necessary' for regulatory precision.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UDAAP_BuriedDisclosures: UDAAP buried disclosure risk: 'including but not limited to'. CFPB targets language that interferes with consumer comprehension. Simplify.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'Correspondent Account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] ProhibitedTerms: Use 'at least [quarterly/monthly/annually]' instead of 'periodically' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] ProhibitedTerms: Use 'at least [quarterly/monthly/annually]' instead of 'periodically' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] ProhibitedTerms: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] ProhibitedTerms: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] ProhibitedTerms: Use 'when [specific trigger condition]' instead of 'as appropriate' for regulatory precision.
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] BSA_BeneficialOwnership: BSA beneficial ownership concern: 'correspondent account'. Ensure CDD documentation explicitly addresses beneficial ownership thresholds and foreign shell bank prohibitions per 31 CFR 1010.230.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[ERROR] UDAAP_DeceptiveLanguage: UDAAP risk: 'may apply'. CFPB flags imprecise conditional language that obscures costs or terms. Provide exact figures and conditions.
[WARNING] ProhibitedTerms: Use 'at least [quarterly/monthly/annually]' instead of 'regularly' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be reported'. Assign clear responsibility with active voice (who does what).
[WARNING] ProhibitedTerms: Use 'at least [quarterly/monthly/annually]' instead of 'regularly' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] ProhibitedTerms: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[ERROR] ProhibitedPhrases: Risky language in BSA/AML document: 'draft'. Examiners interpret this as non-compliance.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[ERROR] ProhibitedPhrases: Risky language in BSA/AML document: 'draft'. Examiners interpret this as non-compliance.
[ERROR] ProhibitedPhrases: Risky language in BSA/AML document: 'draft'. Examiners interpret this as non-compliance.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We shall'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be reviewed'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be conducted'. Assign clear responsibility with active voice (who does what).
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be updated'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be performed'. Assign clear responsibility with active voice (who does what).
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be performed'. Assign clear responsibility with active voice (who does what).
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be performed'. Assign clear responsibility with active voice (who does what).
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'we will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be performed'. Assign clear responsibility with active voice (who does what).
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'staff will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] ProhibitedTerms: Use 'within [X] business days' instead of 'promptly' for regulatory precision.
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'We will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[SUGGESTION] PassiveVoicePolicy: Passive voice detected: 'will be reviewed'. Assign clear responsibility with active voice (who does what).
[WARNING] UnassignedResponsibility: Unassigned responsibility: 'Employees will'. Name the role responsible (e.g., 'The BSA Officer shall...').
[WARNING] ProhibitedTerms: 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

  1. Address all errors before your next examination cycle
  2. Review warnings with your compliance officer or committee
  3. 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

This report was generated by FinCompliance v0.1.0 — the first open-source compliance documentation linter for financial institutions. The analysis covers document structure, regulatory language, required elements, and policy completeness. It is not a substitute for legal or compliance advice.

Report generated: 2026-04-02 13:25:11 UTC