March 4, 1998
Keith J. Orfanides, Internal Auditor
Steuben Educators Federal Credit Union
77 Victory Highway
Painted Post, New York 14870
Dear Mr. Orfanides:
You have asked what date should be considered as the date of the
last supervisory committee audit, the year the audit work actually
was performed or the year of the period covered by the audit.
The appropriate date to use is the date that the audit work was
performed.
You state that the supervisory committee performed an audit the
week of January 29, 1996, for the period of January 1, 1995, through
December 31, 1995, and the week of January 27, 1997, for the period
of January 1, 1996, through December 31, 1996. At present, the
supervisory committee plans to schedule the next audit for the
week of April 28, 1998, for the period of January 1, 1997, through
March 31, 1998. The supervisory committee is concerned that,
by moving the end of the audit period to March 31, 1998, it may
be in violation of �1.12(c)(1). The concern is that, if
1996, the period covered by the audit, is considered the date
of the last audit, there would be a violation.
Section 701.12(c)(1) provides that "[a] supervisory committee
audit of each Federal credit union shall occur at least once every
calendar year and shall cover the period elapsed since the last
audit period." The date that the audit work is performed
is the date that the credit union should consider as the date
of the last audit. Thus, as long as one supervisory committee
audit is performed each year, a credit union would be in compliance
with �1.12(c)(1).
In your case, January 27, 1997, would be considered the date of
the last supervisory committee audit. The credit union intends
to schedule an audit in 1998, and, thereby, would be in compliance
with �1.12(c)(1).
Sincerely,
Sheila A. Albin
Associate General Counsel
GC/NSW:bhs
SSIC 3500 / 97-1111