Question regarding the UDAAP Procedures: Is it reasonable to think that the Operating function and the Control function can be handled by the same group, i.e. Compliance department. For example, the Repricing and Changes in Terms Checklist appears to be a function that would best fit the Compliance dept. in our bank. Would we be criticized by examiners if the compliance dept. handled both Operating and Control functions and then our internal audit department handled the audit function?
