Skip to content
BOL Conferences
Thread Options Tools
#856191 - 11/16/07 06:01 PM Regulatory Due Diligence for Bank Acquisition
Luzmarie Offline
New Poster
Joined: Mar 2007
Posts: 18
The bank I work for is evaluating a possible acquisition of a bank. Are there any checklist or instruments I may use to perform a complete Due diligence of all regs.

Return to Top
General Discussion
#856255 - 11/16/07 06:50 PM Re: Regulatory Due Diligence for Bank Acquisition Luzmarie
1 Peter 5:7 Offline
Diamond Poster
1 Peter 5:7
Joined: Jun 2001
Posts: 1,339
TX
Tall order. Given the usual limited time to do due diligence you can't realistically cover "all regs." So keep it risk based. Assuming the target is a community bank:

Start with looking at recent compliance examination reports and audit reports for quick identification of compliance trouble spots. Do some deep dive reviews in higher risk areas like flood insurance, BSA AML, OFAC, etc. The AML risk assessment should identify high-risk products and services that may hint at their overall compliance risk profile.

Ask for the number and dollar amount of HELOCs, Section 32 loans, ARMs, number of MSB customers, number of CTRs and SARs filed. From there you can tailor more deep dives if the numbers indicate higher risk.

Last edited by 1 Peter 5:7; 11/16/07 11:19 PM.
_________________________
Opinions are mine not my employer's, and should not be taken as legal advice.

Return to Top
#859710 - 11/23/07 02:23 PM Re: Regulatory Due Diligence for Bank Acquisition 1 Peter 5:7
Dollye7 Offline
Gold Star
Dollye7
Joined: Jun 2006
Posts: 255
Southwest USA
I would also review some final TILs against APRWIN (double check the fees), and verify their knowledge of rescission rights.

Return to Top
#859752 - 11/23/07 04:16 PM Re: Regulatory Due Diligence for Bank Acquisition Dollye7
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Also ask for the policy and procedures manuals and exception reports, lending and deposit, and customer complaints.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#861600 - 11/27/07 11:40 PM Re: Regulatory Due Diligence for Bank Acquisition Kathleen O. Blanchard
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,763
On the Net
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#863434 - 11/30/07 12:17 AM Re: Regulatory Due Diligence for Bank Acquisition Andy_Z
cbinder63 Offline

Platinum Poster
cbinder63
Joined: Dec 2001
Posts: 674
Colorado
Review a sample of the Flood Determinations for completeness and accuracy. Look at the CRA Public File for skeletons. Evaluate the training reports for required training, and especially required not attended training (may point to other issues).
_________________________
Opinions expressed are my own.

Return to Top
#864102 - 11/30/07 07:03 PM Re: Regulatory Due Diligence for Bank Acquisition cbinder63
I Wear Many Hats Offline
Platinum Poster
I Wear Many Hats
Joined: Mar 2001
Posts: 591
the beautiful state of ME
See who their vendors are - you may find that you use some common vendors which may make your due diligence a little easier - for example, if you both use the same vendor to do flood zone certifications, credit reports, etc., you will have a better comfort level than looking at vendors you've never heard of!
_________________________
The paradox of planning is nothing happens....

Return to Top