Compliance Exams

As often happens, the agencies are adjusting their approach to compliance examinations. This time, the focus is on the compliance program. Both FDIC and OCC will take a top-down look at banks to evaluate the compliance program rather than to use regulatory checklists or work product by product. Examiners will be looking at the level of management commitment and involvement to the compliance program. The assumption behind this approach is that an effective program with management support can identify problems as they occur and develop preventative measures or remedies.

Other changes may have more impact on your relationship with your examiner. The OCC is moving to an ongoing examination cycle. Rather than dropping in for a full-scope examination every few years, the OCC compliance examination will be a continuing process. While there are probably situations where it may seem like never-ending, the OCC hopes that this approach will be less burdensome on and less disruptive to the bank.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 14, 12/02