Supervisors Symposium - December 2023

CONFIDENTIAL

MMET Supervisory Highlights Common Exam Findings:

 Financial • State specific issues—deficient permissible investment coverage, inadequate net worth • Call Report errors—inaccurate volume, slotting errors, late filings • Missing, inaccurate or deficient written policies and procedures (escheatment, write-off, reconciliation, VC asset verification)  Compliance • Missing, inaccurate or deficient written policies and procedures (OFAC, AML, CIP & KYC) • SAR violations (late filings, incomplete filings) • Insufficient transaction monitoring & improper disclosures

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CONFIDENTIAL

MMET Supervisory Highlights (continued) Common Exam Findings:

 Management • Failure to notify re: staffing changes

• Lack of defined policies and procedures for succession planning • Business continuity concerns stemming from exam scheduling issues • IT concerns—failure to perform IT risk assessment, vendor management issues

(overreliance on 3 rd parties, lack of due diligence) • Failure to provide all requested exam materials

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