Question & Answer

Question: My bank's CEO has asked me for suggestions about how the bank can prepare for compliance examinations to shorten the amount of time examiners spend in the bank. We are particularly concerned about the length of time that a fair lending exam can take. What are your recommendations?

Answer: The best way to shorten the length of a compliance examination is to do it first. Examiners will use your internal audit and self-assessment reports if they are thorough, accurate, and timely.

Examiners find that the length of time they spend on fair lending examinations depends on the work already prepared by the bank. Generally, they will review your work and build on it. Thus, if you conduct a thorough fair lending assessment that includes the steps and analysis in your regulator's procedures, you will significantly shorten the amount of time the examiners need to spend in your bank. Your CEO has given you an ideal opportunity to get support for your compliance program. This is the time to get approval for strengthening monitoring procedures or increasing the scope of your compliance audit because you are able to show what savings will result from the increased investment.

Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 10, 6/96