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#113695 - 09/10/03 06:15 PM fdic compliance exam
Anonymous
Unregistered

Sorry this is anonymous. I'm not at my computer and can't remember my password. My question - has anyone had an FDIC compliance exam since June 1 (when the new exam procedures were put into place)? How did the exam go? Were there any hot buttons? Were the procedures completely different than past exams or did things go pretty much as usual? We have them visiting soon and I would like to be prepared. I did pull down the exam procedures from the FDIC website but am curious what the exam was like in the real world. Thanks for any info...Colleen

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#113696 - 09/10/03 06:49 PM Re: fdic compliance exam
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
We had our exit meeting yesterday. Things were very different in my opinion. They only looked at 8-10 files total and the package we forwarded to the FDIC prior to the exam was quite large. They interviewed several employees about policies and procedures and that went well.

As for hot buttons - Flood and HMDA are the two biggies. Order lists from your flood vendors for properties they are tracking for you and review those files for the proper amount of insurance and that the policy is in force.

I think, all in all, it was smoother than previously, but that's my opinion.
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#113697 - 09/10/03 07:39 PM Re: fdic compliance exam
Anonymous
Unregistered

Thanks for sharing your experience. What "type" of employees did they interview....management? tellers? loan officers? Also, how was the privacy part of the examination conducted? Any surprises on that?

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#113698 - 09/10/03 07:46 PM Re: fdic compliance exam
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
They interviewed people for HMDA, truth-in-savings, fair housing and fair lending (mortgage originator; manager of deposit operations and manager of loan operations). We chose who they would interview.

They reviewed our privacy notices, both initial and annual for privacy. That's about all they did there.
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#113699 - 09/11/03 04:57 PM Re: fdic compliance exam
Jayda's Mom Offline
100 Club
Joined: Jul 2002
Posts: 220
North
We had our exam in August and it too went relatively smooth. They focused a lot on our risk assessments for audit as well as the audit function in general. Being that the Oct. 1 deadline is nearing for CIP you can bet that they will be reviewing your BSA program-specifically CIP and AML policies.

Good luck!

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#113700 - 01/08/04 06:31 PM Re: fdic compliance exam
MackenzieS Offline
Diamond Poster
MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
I am resurecting this post to see, now that more banks have gone through the new exam procedures for compliance, if you have anything more to add to how the process went.

Was the time in house shortened due to the amount of documentation reviewed offsite? Was the Compliance officer allowed to sit in on any discussions with the other employees? Do they really talk with the Board to find out their working knowledge for compliance issues? etc...

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#113701 - 01/09/04 08:55 PM Re: fdic compliance exam
Carrie Offline
Member
Carrie
Joined: May 2002
Posts: 74
Pittsburgh, PA
We had our exam in November. It really was much different. The examiner focused primarily on internal oversight and management involvement. She read each internal audit that had been conducted since the prior exam, looked at the mechanisms for reporting to the Board, and interviewed those responsible for specific areas of compliance. She looked at very few loan files and didn't review many operational areas. It was all very "risk-focused". We had merged with another bank and undergone a data processing conversion during the year and she looked at compliance areas relating to these issues (i.e. the loan files that she did look at were from the two newly acquired offices). All in all it was not a bad experience.

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