Examiner's Recommendations
Question: We just had an exam and got a good rating. But the examiner still made lots of suggestions to us. Are we obligated to do everything the examiner suggested? And if examiners do this at every exam, where does this end?
Answer: First, you are not obligated to do everything the examiner suggested unless there is a clear mandate. And if the examiner means that unless you do this you will have problems, the message will be very clear. However, the regulatory agencies have come to recognize that they can add value to the examination process by sharing best practices that they see in other institutions. While some examiners may clearly be making suggestions, others may make it sound ominously like an order, but the bottom line is the same. These are recommendations intended to provide you with ideas to consider. And while you should consider them, you are not obligated to incorporate them into your institution unless the idea is a good fit. You can also get ideas from other compliance managers. So give yourself a little break and schedule lunch with some peers from around town.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 7, 6/05
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