Extract to table

This objective must be completed by June 30, 2025, with an interim milestone of 75% completion (approximately 1,800 alerts) by April 30, 2025

The Lookback documentation will support the Comprehensive Remediation Action Plan (due to the OCC by May 15, 2025) and the compliance self-certification that BRB must submit to the OCC by February 15, 2026

No sampling is applicable to this population; every alert must be fully investigated and dispositioned

For alerts resulting in SAR filings, the SAR must be prepared and filed within 30 days of the Lookback investigation team's determination that a filing is warranted

For alerts resulting in closure, a closure memorandum documenting the investigative analysis and the specific rationale for the decision not to file must be prepared and retained in the alert investigation file

Any changes to the sampling methodology after the commencement of the Lookback must be documented and approved in writing by the BSA Officer (Thomas Ikeda), Calderwood & Harkness (Philip Hartmann or Yuki Nakamura), and Thornfield Consulting