One thing that can be easily overlooked when it comes to SAFE Act compliance is the requirement for an independent test. An independent test must be conducted at least annually and can be performed either by internal bank personnel or a third party. If you opt to keep it in house, you need to ensure that the person conducting the audit is not your SAFE Act officer and that they have the appropriate knowledge and/or training to be able to conduct a sufficient audit.
Jerod explains more in the video.
2025/11/06