Internal Audit Data Quality

Anthony Tse, CPA

**-** **** *****, ***#*D, Rego Park, NY 11374 § ad5nt3@r.postjobfree.com § 929-***-**** § linkedin.com/in/anthony-tse-cpa-7635bba

EXECUTIVE AUDIT MANAGEMENT

Accomplished audit professional with extensive experience combining internal audit, regulatory compliance and SOX compliance expertise to foster efficient and cost-effective operations for leading financial institutions. Well known for his strong leadership to develop and coach the internal audit team in the skills required to deliver high-quality audit, his interpersonal skills to communicate within all levels of internal audit team and C-suite executives, and his technical knowledge in commercial banking to respond to complex regulatory environments.

Professional Experience

QA TRANSFORMATION CONSULTANT July 2023 – April 2024

CITIGROUP – SERVICES, MARKETS, BANKING & CLIENTS – QA TRANSFORMATION – SENIOR VICE PRESIDENT

Facilitate Citigroup Services, Markets, Banking and Clients (SMBC) QA Transformation engagement across the full lifecycle of high impact issue remediations and key remediation programs, as related to a pair of consent orders issued in 2020 by the Federal Reserve Board (FRB) and the Office of the Comptroller of the Currency (OCC). Act as project lead for SMBC Transformation Director and action owners to advise on the effective design and implementation of key control remediations surrounding data governance and risk and control framework.

Build good relationships across the SMBC Businesses (first line) to ensure remediation design and implementation is effectively project managed and executed in co-ordination with second line (Risk) and third line (Internal Audit).

Lead QA review on sustainable adoption of technology architecture to govern Product-Market-Model (PMM) combinations with the coverage of:

oBreak Review and Remediation: QA the Price Risk & Control Team (PRC) break validity review and false positive check, escalation to Market Quantitative Analysis Team (MQA) to remediate model dependency breaks, escalation to Trading Business Team to remediate master product to primary model and market scope (maximum tenor/currency pair) breaks, to mitigate against the unintended model use outside of the permissible PMM combinations.

Data Quality Exceptions and PMM Breaks Reporting: QA the PRC weekly review of data quality exceptions (missing or invalid product ID/model ID/currency pair) with Front Office Technology and MQA teams for remediation, monthly reporting of data quality issues to Data Quality Business Sub-forum, and monthly escalation of PMM breaks to Valuation Risk Council.

Spearhead QA review on Institutional Credit Management (ICM) Commercial Loans & Commitments – Operations Booking Controls against the applicable Data Quality Minimum Requirement Controls (DQMRCs) as derived from the Data Quality Control Assessment (DQCA), with the coverage of:

oData Entry and Amendment Validation: Review the validation of manual entry of data to ensure the accuracy of data input and amendments (e.g. via maker-checker control).

oExternal Third-Party Data Review: Review the reconciliation of internal Citi Product Process data vs. external custodian was timely performed, to ensure that any breaks were escalated and resolved, and to ensure compliance with regulatory obligations and policy requirements.

oImplementation of Data Quality Rules: Review the implementation of data quality rules that met the valid definition (e.g. format, type, size, structure) as data travelled end to end.

oReview of Data Quality Rules: Ascertain that Business Data Quality Governance Forum reviewed the aggregate monthly data quality statistics, to validate if the data quality rules were performed as expected vs. if any erroneous or missing data quality rules were identified, so that data quality rules could be subsequently updated to correct errors.

oData Consumption from an Approved Source: Ensure review of data sources was performed to confirm that data being consumed is from an approved system of record (SOR) and/or authorized redistributor (AR).

oAdjustment/Correction Tracking: Validate that a pre-adjustment to post-adjustment review was performed by data consumers to track the rationales for adjustments or corrections made to financial data, including the sign-off obtained for material adjustments made. Verify that inventory of full population of adjustments was maintained.

oMonitoring of Exception Reports: Review the monitoring of data quality exception reports, to ensure any data quality exceptions were properly documented in the Data Concerns Remediation Management (DCRM) tool.

oTracking Data Defects to Remediation: Verify that data quality exception reports were presented and reviewed monthly by the Business Data Quality Governance Forum, to ensure that data defects were timely addressed and remediated.

oData/Report Delivery Completeness and Timeliness: Verify a quarterly review over data/report completeness and timeliness was performed against the established production calendar, to confirm adherence to Service Level Agreements (SLAs) and minimize delays in data submission.

Oversee QA review on Institutional Credit Management (ICM) Counterparty Exposure Team - First Line of Defense Credit Approval process with the coverage of:

oCitigroup Inter-affiliate: annual designated legal entity check, credit memo extension review, margin dispute escalation, non-financial scorecard attestation, staff training.

oCitigroup Agency Lending: new counterparty approval, monthly portfolio review, approval of non-standard terms in legal agreements, provision of system access.

Spearhead QA review on Lending Transformation Program, including the design and implementation of enhanced program governance for Loan IQ implementation (i.e. Loan Operation Technology Steering Committee (LOTS) charter, LOTS membership & meeting & quorum requirements, senior governance structure and Loan IQ delivery sub-forum), progress monitoring metrics, conversion risk exception management and oversight, tri-annual plan review over milestone changes.

Lead QA review on Lending Transaction Management (TM) Documentation Checklist QC process with the coverage of:

oDocumentation Checklist Change Management: QA the annual review of TM Documentation Checklist against the Citigroup Institutional Client Group Credit Policy to ensure alignment.

oPre-close Documentation Checklist Review: QA the pre-close Transaction Management maker/checker review of documentation received against TM Documentation Checklist, to ensure the collection and storage of required documents at loan closing.

oPost-close Documentation Checklist Review: QA the post-close Transaction Management Controller’s independent quality control review of the loan and supporting documentation captured at LYNX by the TM team, against the TM Documentation Checklist.

CTBC BANK, NEW YORK BRANCH March 2020 – July 2023

INTERNAL AUDIT – VICE PRESIDENT

Overseed the New York Branch (NYB) Validation Assessment Projects resulting from Examiner (Federal Reserve Bank of New York, New York State Department of Financial Services), Third Party, and Internal Audit recommendations. Reported results (overdue vs. validated vs. in validation vs. not due) on a monthly basis to Head Office Internal Audit Department.

Developed and executed validation testing methodology. Provided validation guidance to junior team members.

Led/executed the Commercial Lending Internal Audit which was assessed as high risk in the annual risk assessment.

oEvaluated the presence of approval and completeness of loan application for new and renewed loans:

Validated the credit review and approval process via completion of credit application form and credit analysis report, and credit approval provided by Head Office and/or NYB local management in accordance with Obligor Risk Rating (ORR). Validated the completion of the credit application checklist which secondarily ensures that all documents required for the credit approval process were reviewed.

Inspected that site visit was conducted as part of credit approval process.

Inspected that due diligence was performed on borrower’s financial status via review of borrower/guarantor’s audited financial statements, tax returns and rent rolls.

Validated the effectiveness of collateral valuation (i.e. property appraisal), property/liability/flood insurance, and UCC-1 filing for credit facilities secured by real estate properties.

Validated the consistency of terms and conditions among term sheet, credit agreement, promissory note, commitment letter, guaranty agreement, security agreement and other legal document as required.

Inspected that financial reporting and financial covenant requirements were set up in the Post Lending Management System (PLMS) at the frequency and recurring dates as required per term sheet.

oExamined the adequacy of the post lending management processes related to the interim and annual review cycle, and quarterly compliance checklist.

oEvaluated the adequacy of the early-warning management process over the identification/monitoring of loan delinquencies, past due/non-accrual, charge-off and recovery, criticized loans, and restructured debt activities.

oReviewed the Allowance for Loan and Lease Losses (ALLL) activities in accordance with US GAAP.

oInspected that insurance is sufficient to cover the value of loan collateral. Review the controls over instances of force-placed insurance (if applicable).

oReviewed the adequacy of control over collateral valuation for real estate lending, via cost/income/market value approaches of valuation. Verify timely renewal of Uniform Commercial Code (UCC) filing prior to expiration. Review asset-based lending via re-calculation of eligible AR and Inventory in borrowing base certificate.

oExamined the monthly monitoring and reporting of loan portfolio concentration limits (i.e. top 10 customers by credit outstanding and unused commitment not to exceed 50% of NYB’s credit exposure, top 10 customer packages within 60% of NYB’s credit exposure, individual industry within 25% of NYB’s credit exposure while real estate industry within 35% of NYB’s credit exposure, total leverage lending customers within 35% of NYB’s credit exposure).

oReviewed the actions taken by management to sufficiently manage the LIBOR transition project.

oInspected the targeted annual technical training for commercial lending was provided to Marketing, Risk, Credit and Credit Administration staff.

oReviewed the compliance of regulations as applicable to commercial lending (i.e. Regulation B - Equal Credit Opportunity Act, Regulation O - Loans to Insiders, Regulation K - Legal Lending Limits)

Led/executed the Loan Operations Internal Audit which was assessed as medium risk in the annual risk assessment.

oEvaluated the controls in place to govern loan drawdown process, including the initial credit application form, loan limit transfer to FCC system (i.e. the core banking system), term sheet verification, timely completion of annual review and interim review, loan drawdown application approval, and accuracy of drawdown recorded in the FCC system.

oAssessed the controls in place surrounding the loan payment function, including timely settlement and application of loan payments, accurate booking of loan payment interest and principal components in FCC system.

oReviewed the preventative control within the FCC system to prevent drawdown on matured loans. Inspected loans pay-off were processed by pay-off notification, FCC system booking and facility closure in FCC system, and timely processing of collateral release (i.e. applicable for loans secured by real estate property and CD).

oEvaluated that credit term amendment (i.e. loan interest rate change, maturity date change, tenor change, interim review/annual review date extension, financial statements due date extension) and commercial loan refinancing (i.e. interim increase of facility limit, loan extension at maturity) activities were both properly authorized and accurately entered into the Credit Processing System (CPS).

oEvaluated that market interest rate changes (i.e. Prime, LIBOR, SOFR) were timely communicated and properly approved, with the subsequent loan repricing transactions accurately processed in the FCC system.

oAssessed that file maintenance changes were supported with documentation, and a month-end maker-checker review of the file maintenance report was performed to detect against unauthorized changes to customer profile.

oReviewed all incidents reported at Loan Operations during the audit period. Ensured root cause analysis was performed per incident by management, and the necessary remediation measures were timely implemented.

Led/executed the Borrower in Custody (BIC) Collateral Program Audit which was assessed as high risk in the annual risk assessment.

oThis audit aimed to assess NYB’s compliance with FRBNY’s BIC collateral program requirements and qualification to secure borrowings from the Discount Window. Key Audit Objectives:

Assessed the adequacy of documented policies and procedures.

Assessed whether loans pledged as collateral comply with the eligibility, acceptable internal loan risk ratings, and documentation requirements of the FRBNY BIC Program.

Assessed the custodial controls related to identification, physical security & segregation of pledged loans collateral.

Tested controls over data submission, collateral updates (monthly reporting, annual certification) & monitoring.

Led/executed the Funds Transfer Internal Audit which was assessed as high risk in the annual risk assessment.

oEvaluated the design adequacy of remittance/deposit policies & procedures on manual and systematic wires, remote check deposit and incoming checks, ACH, and the applicable regulations.

oRevamped audit program to develop best practice testing strategies for the funds transfer sub-processes:

Wires (Manual & Systematic):

Reviewed OFAC screening, wire threshold & authorization requirement, safekeeping of customer signature cards.

Reviewed repair queue timely resolution on non-straight through processing systematic wires, call back procedure and signature verification on customer initiated (manual) wires via e-mail or fax, Regulation E – preauthorized transfers and signature verification for repetitive internal wires among customer accounts.

Automated Clearing House (ACH):

Audited outgoing ACH debits by reviewing call back on customer money transfer applications and customer signature cards; audited Regulation E - preauthorized transfers impacting incoming ACH debits by reviewing customer pre-authorization letters and customer signature cards; inspected customer agreement disclosure regarding pre-authorized transfers on customer's account and customer's obligation to review periodic account statements distributed to timely escalate any discrepancies.

Reviewed incoming ACH debit returns to ensure unprocessed ACH items were timely credited to customer accounts; reviewed incoming ACH credit returns to ensure unprocessed ACH items were timely returned to originating banks.

Reviewed ACH business continuity program, ACH vendor management and service level agreement with service provider Bank of New York Mellon (including SOC 1 Review).

Remote Check Deposit (RCD):

Reviewed Regulation CC – Expedited Fund Availability Act applicable for RCD customer transactions.

Reviewed onboarding & periodic training for RCD customers, annual suitability review, complaint log review, RCD physical checks retention & storage & destruction, RCD business continuity program, RCD vendor management and service level agreement with service provider Bank of New York Mellon.

Incoming Check Returns & RCD Returns:

Examined both incoming check refunds provided by FRB were credited to customer accounts timely, and RCD returns unpaid by drawee banks were debited to customer accounts promptly.

End of Day Reconciliation:

Re-performed end of day GL account to FED/Bank of New York Mellon reconciliation for wires, RCD and ACH; validated the supervisory review and timely escalation of discrepancies (if applicable).

Examined the segregation of duties between the reconciliation function and the funds receiving/processing/sending function.

Led/executed the Deposit Operations Internal Audit which was assessed as high risk in the annual risk assessment.

oAccount Opening (savings, checking, CD):

Reviewed signature card, proper interest rate, OFAC check and CIP review documentation.

Reviewed formality of customer request for internet banking access, including due diligence performed to assess the risk of unlawful internet gambling as related to Regulation GG - Unlawful Internet Gambling Enforcement Act of 2006.

Validated conspicuous disclosures supporting Regulation DD - Truth in Savings were provided to new customers.

oAccount Closing (savings, checking, CD):

Inspected closed CD accounts prior to maturity for the accuracy of interest penalty assessed, inspected closed CD accounts at maturity date to recalculate the accuracy of the principal and interest paid.

Verified NYB notified all customers on CD accounts on maturity date via customer statement distribution.

Verified call back procedure timely conducted by Operations for closed checking and savings and early terminated CD requests (via faxes, e-mails and physical mails) with the money moving out to external accounts.

Reviewed monitoring activities conducted by Operations against zero balance accounts on the system.

oDormant/Escheat Account Monitoring:

Inspected the system control over classification of dormant account (after 2 years of inactivity) vs. abandoned account (after 3 years of inactivity).

Inspected the communication provided to dormant account customers to either instruct NYB to re-activate or to close accounts; inspected the actions taken over abandoned account after 3 years of inactivity, such as removal of customer access to account, and corresponding reporting transferring balances to the NY State.

oAccount Maintenance:

Reviewed customer statement mailing and returns for checking/savings accounts, including required disclosure such as fee assessment, annual percentage yield calculations, descriptions for electronic transactions, and a phone number to contact with any questions the customer may have concerning the statement.

Tested Regulation D - Reserves requirements over the withdrawal limits for saving accounts.

Reviewed controls over hold fund according to funds availability policy, and stop payment.

Led/executed the Corporate Compliance Internal Audit which was assessed as high risk in the annual risk assessment.

oReviewed Compliance Committee Charter, Three Lines of Defense Framework, Corporate Compliance Risk Assessment (CCRA) Methodology, Inventory of Applicable Regulations, Corporate Compliance Staff Skill & Capacity Gap Assessment, Fraud Program & Whistle-Blower Program, and Customer Complaints Handling.

oAssessed the Compliance Monitoring and Testing (CMAT) program per regulatory requirements FRB SR 08-8, including review frequency per selected regulation, review dates evenly spread out in the next 36 months, and mapping from CCRA to CMAT program (i.e. the assurance component).

oEvaluated Branch Wide Risk Assessment citing all NYB applicable regulations. Assessed the regulatory compliance by testing the combination of 1st line of defense (Policies & Procedures, Trainings), 2nd line of defense (Compliance Self Evaluation, CMAT Program) and 3rd line of defense (Internal Audit Review).

oValidated Corporate Compliance enhanced its Annual Training Plan coverage to include all applicable regulations.

Led/executed the BSA AML OFAC Compliance Internal Audit which was assessed as high risk in the annual risk assessment, with the focus on Know Your Customer (KYC) including Customer Identification Program (CIP), Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD).

oReviewed the sufficiency of CIP documentation maintained, and ensured the screening of customer name and related parties against applicable list issued by federal government agency on USA PATRIOT ACT – Section 325. Tested the procedure for updating beneficial owner information for existing customers on an ongoing basis.

oExamined the customer risk rating methodology for evidence of assigning risk ratings to account holders using factors as geographic risk, customer risk, product and service risk, transaction risk, behavior risk. Review risk rating modification process after periodic refresh.

oInspected the timely completion of periodic review (including both CDD & EDD periodic reviews) based on risk rating of customers, Sanctions & Politically Exposed Persons & Negative News screening of newly added connected parties, relationship-wide review for customers with multiple accounts.

oAssessed the effectiveness of enhanced due diligence process, including due diligence of PEPs, site visitation, transaction analysis (actual activity vs. expected activity), relationship-wide review for complex customer relationships, event-driven reviews, annual Quality Assurance (QA) review over whole EDD population.

Co-led/executed the Quality Assurance (QA) Review over NYB Internal Audit, within the Internal Quality Assurance and Improvement Program initiated by Head Office Internal Audit.

oConducted QA review by adhering to guidance provided by FRB SR 13-1 Supplemental Policy Statement on Internal Audit Function and it Out-sourcing, including:

Enhanced Internal Audit Practices.

Internal Audit Function (Attributes of Internal Audit, Corporate Governance Considerations, Adequacy of Internal Audit Processes including Audit Methodology and Audit Universe and Internal Audit Risk Assessment and Internal Audit Plan and Continuous Monitoring, Internal Audit Performance and Monitoring Process including Internal Audit Scope and Internal Audit Work-papers and Audit Report and Issues Tracking).

Internal Audit Outsourcing Arrangements (Vendor Competence Review, Contingency Planning, Review the Quality of Audit Work per Vendor).

oConducted QA review over the Planning Phase, Fieldwork Phase and Reporting Phase of selected audits:

Planning Phase: Mapped H/M/L rated risk categories, primary risk vs. secondary risk per process, business units & corporate functions from Annual Risk Assessment to Audit Planning Memo and Risk Control Matrix; reviewed design of controls for risks mitigation; reviewed status of closure of prior audit issues and reference to recent regulatory examination issues; reviewed timely sign-off of audit planning documents at audit system prior to fieldwork start date.

Fieldwork Phase: Reviewed process walkthrough and narrative completion, mapped audit scope described in Audit Planning Memo to test-work performed; reviewed sufficiency of test steps to address stated controls; reviewed adequacy of workpaper documentation to support conclusion reached; reviewed sampling methodology and rationale, reviewed timely sign-off of testing/workpapers at audit system prior to final audit report.

Reporting Phase: Reviewed timely preparation of draft audit report including disposition of audit issues, root cause analysis, recommendations and management action plans; reviewed timely distribution of final audit report within 30 calendar days of the completion of fieldwork.

INTERNAL AUDIT CONSULTANT December 2018 to March 2020

MORGAN STANLEY – FINANCIAL CONTROL GROUP – SENIOR AUDIT MANAGER (January 2020 to March 2020)

Supported the Finance Risk & Assurance in its compliance certification of the 17a-5 Broker Dealer Regulatory Compliance Program, which includes the testing of 15c3-1 net capital calculation, cash management, and customer statements, etc.

CIT GROUP – PROFESSIONAL PRACTICES GROUP – AUDIT MANAGER (December 2019 to January 2020)

Led Quality Assurance Review (QAR) of audit projects over Accounting Support Group, New Activities Governance Framework, and Capital Planning Aggregation & Reporting, as performed by Internal Audit to ensure audits were executed in accordance with CIT audit methodology and standards.

CTBC BANK, NEW YORK BRANCH – INTERNAL AUDIT SENIOR CONSULTANT (June 2019 to December 2019)

Led the Validation Assessment Project to review the corrective actions (strategic & tactical) taken to address the design effectiveness issues identified during the FY 2018 BSA AML Compliance Audit. Reviewed the sustainability of controls updated in the policies & procedures for On-boarding, CDD/EDD, OFAC, Transaction Monitoring, and SAR.

BANK OF COMMUNICATIONS, NEW YORK BRANCH – SENIOR AUDIT OFFICER (December 2018 to May 2019)

Completed three FY 2018 past due commercial banking internal audit projects (i.e. Trade Finance, Treasury – Investments, Financial Institutions - Correspondent Banking) by Q2 2019.

BDO USA, LLP – New York, NY 2014 to 2018

Experienced Manager, Risk Advisory Services

Led internal audit and SOX compliance projects for financial services clients. Key Audit Responsibilities:

Grew business practice by adding new clients and expanding service of existing clients. Successfully identified business opportunities and generated a total of $1.5M service revenue based on internal audit outsourcing, validation assessment and quality assurance review provided to three foreign banks during fiscal years 2017-2018.

Facilitated a foreign banking client to reduce two-thirds of its number of regulator MRIAs and MRAs during FYs 2017-2018, by providing expert advice through a BDO team of SMEs, including IT & Cybersecurity, BSA/AML, and Commercial Lending.

Actively participated in meetings with regulators including OCC, NYDFS and FRB New York, and provided answers to inquiries regarding progress of risk assessment, internal audit projects and issues validation projects.

Interviewed with client senior management to understand their roles and responsibilities within the client organization, risk factors and risk ratings, risk mitigation strategies and strength, for the purpose of performing risk assessment and scoping.

Supervised and executed the Lending internal audit projects for two foreign banks. Loan Origination Audit includes review of commercial real estate loan & syndication loan origination, underwriting exceptions to credit policies, loan renewal, lending authority. Loan Portfolio Management Audit includes review of past due loans and collections, ALLL, foreclosures, OREO, charge-off and recoveries. Loan Operations Audit includes review of new loan set-up & verification, loan disbursement, loan pay-off, loan fees & accrued loan interest, loan sub-ledger to GL reconciliation, interest rate changes.

Executed the Regulatory Compliance internal audit project for a foreign bank including the review of Regulation B - Equal Credit Opportunity Act, Regulation H - Flood Insurance Act, Regulation V – Fair Credit Reporting Act.

Oversaw the Validation Assessment project for a foreign bank to review the actions taken to address the findings identified by its Advisor, Head Office Audit Department and outsourced BDO internal auditors.

Executed the External Quality Assurance review of two foreign banks including the review of internal audit function, internal audit activities, audit reports and audit work-papers in conformance with IIA standards.

Supervised SOX 404 compliance projects for three financial services - asset management clients and one pharmaceutical client. Primary responsibilities include:

oEnhanced documentation on review controls to reflect evidence of multi-level management review.

oBuilt Risk and Control Matrices and testing plan to audit on advisory fees revenue, investment valuation, sales and trading execution, management fee/incentive fee/administration fee calculation, income tax, fixed assets, payroll, human resources, and financial statement close, etc.

oMapped the seventeen underlying principles within the five interrelated COSO components of the 2013 COSO Framework to organization’s entity level controls.

Spearheaded Information Technology General Controls review over banking, real estates and not-for-profit clients. Key audit areas include:

oIT organization, administration and governance.

oSystem development, acquisitions and program change management.

oAccess to programs and data (user access addition and deletion, super-user/administrator controls, operating system and application access security).

oComputer operations, cyber security review and enhancement.

INTERNAL AUDIT & SOX COMPLIANCE CONSULTANT 2013 to 2014

Brookfield - Sox Audit Manager (2013 – 2014)

Supported Brookfield Property Partners to ensure compliance with SOX 404 readiness during first 12 months of its initial public offering at the US, including reviewing management review controls in alignment with PCAOB auditing standards.

mitsubishi ufj - Audit Lead, Liquidity Risk Management (2013)

Examined sources and uses and liquidity gaps projected by daily cash flow report. Verified the reliability of sources and concentration, including liquidity back-stops that would reduce liquidity and become unavailable for liquidity reporting.

Reviewed liquidity stress testing & remediation triggers for sufficiency, length of time for the various survival horizons limits.

Audited Contingency Funding Plan, early warning triggers, and completeness of testing.

LAZARD - Senior Auditor Of SOX (2013)

Conducted SOX test work on financial advisory, mutual fund administration, management fees & incentive fees.

ERNST & YOUNG LLP – New York, NY 2011 to 2013

Senior III Of Advisory Services – FSO/Risk/Process & Controls

Leveraged deep expertise in compliance, risk, data integrity, and quality assurance to provide sound consultation to leading financial institutions including JP Morgan Chase, Barclays, American Express, Freddie Mac, and PNC Bank.

Strengthened management policies surrounding Deposit Operations and

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