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#1149064 - 03/20/09 07:57 PM FACT Act Exam
Jayhawker Offline
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Jayhawker
Joined: Oct 2004
Posts: 93
What exactly does the OCC mean by a "horizontal" review? Is this like the off-site exams they have been performing for CRA????

Thanks

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#1149579 - 03/23/09 03:06 PM Re: FACT Act Exam Jayhawker
Mrs. Rizzo Offline
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Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
I believe they meant it would not only be in the Compliance exam but also in Safety and Soundness.
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#1155994 - 04/01/09 08:30 PM Re: FACT Act Exam Mrs. Rizzo
Mrs. Selby Offline
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Joined: Feb 2003
Posts: 138
Iowa
I always believed it to mean in comparison to peer banks.
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Opinions are my own, not those of my employer, and should not be construed as legal advice.

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#1156103 - 04/01/09 09:32 PM Re: FACT Act Exam Mrs. Selby
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
In my experience, when the OCC speaks of horizontal reviews they are talking about reviews of a cross-section of banks with a particular exposure, like commercial real estate.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
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#1156333 - 04/02/09 01:56 PM Re: FACT Act Exam Kathleen O. Blanchard
smith Offline
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Joined: Jun 2004
Posts: 69
Nebraska
I would agree with Kaybee that "horizontal" means an exam that looks across your bank's different business units.

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#1157189 - 04/03/09 02:41 PM Re: FACT Act Exam smith
John B Offline
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Joined: Apr 2009
Posts: 13
CT
The most recent ABA Bank Compliance Magazine has an article that addresses: http://www.aba.com/NR/rdonlyres/932C30CA-5F64-11D5-AB86-00508B95258D/58356/BCMA2009CoverStory.pdf
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