During this formative stage, it is important to lay a solid foundation for an effective on-going compliance program. Accordingly, ICS will:

• Develop the compliance program
• Evaluate the Bank’s CRA plan
• Develop a product matrix from loan products and deposit products
• Identify and review required disclosures and notices
• Analyze system capabilities to generate disclosures and notices
• Develop customized compliance policies and procedures, including:
• Anti-money Laundering
• OFAC
• Expedited Funds Availability (Regulation CC)
• Electronic Fund Transfers (Regulation E)
• Review main office and branch signage and notices
• Interview bank personnel for compliance readiness
• Provide initial compliance training for all staff
• Complete pre-opening checklist and documentation
• Coordinate pre-opening examination