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#142555 - 12/22/03 10:00 PM FDIC EXAM
Georgia Golfer Offline
Gold Star
Georgia Golfer
Joined: Jun 2003
Posts: 415
1st Tee
I was elected as the compliance officer less than 1 month ago and have just found out that the FDIC will be here in the 1st QTR for a compliance review...Merry Christmas to me!! I thought about posting this in another forum, but I feel a rant coming.... Seriously, any suggestions for getting prepared for this thing without having it dominate my next few months?? Many thanks

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#142556 - 12/22/03 10:01 PM Re: FDIC EXAM
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Quote:

any suggestions for getting prepared for this thing without having it dominate my next few months?




OK now that was funny!!!!

Let it dominate...or leave the country
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Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#142557 - 12/22/03 10:06 PM Re: FDIC EXAM
Bartman Offline
Diamond Poster
Bartman
Joined: Oct 2000
Posts: 1,191
Springfield
Ah, the baptism by fire - I remember it well. (This was me in 1990...)

Look, whatever is "wrong" with the bank can't reasonably be fixed before they arrive. Your best move is to a) respond quickly and thoroughly to their pre-exam questionnaires; b) get department managers involved in the process; and c) start to develop the outline of your compliance program.

If you've had time to review different areas, the "here's what I've found and here's how we propose to fix it" approach works well.

Finally, don't kid yourself - this WILL dominate your next few months. But that's a good thing. Look at it like this: your regulator is giving you a road map for the next 6-12 months of your life. Good luck!
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Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."

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#142558 - 12/22/03 10:18 PM Re: FDIC EXAM
jcrump Offline
Member
jcrump
Joined: Aug 2002
Posts: 88
Texas
I agree with Bartman. This same thing happened to me in 1996, but to complicate things, we had been hit with a rough report the previous exam. Bartmans' advice does work...that's how I met one of my very best buddies, who just happens to now be an ex-examiner. Remember that if the report is not so stellar, it's a reflection of the bank, not you since you just came onto the scene. And, it's an opportunity for you to come in and whip things into shape after they leave. The next exam will likely be much better.

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#142559 - 12/22/03 10:25 PM Re: FDIC EXAM
MackenzieS Offline
Diamond Poster
MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
I was in your same position when I became the Compliance Officer several years ago. Unfortunately for me, my ego got the best of me and I tried to "know it all" before they came in. I worked myself into quite a panic trying to read and understand EVERYTHING before they got there which is an impossible task in and of itself!

The best advice that was ever given to me was when an examiner comes in and asks you a question that you do not know the answer to don't hesitate to tell them that you will look into it and get back with them. Unfortunately this really intimidated me when they did this. You feel like you should have the answer to every compliance related question they ask because after all...you ARE the Compliance Officer right? But just remember too, that they sit in your conference room with a copy of the regulations out on the desk perusing through it as they perform the exam.

Look over the documentation/information requests and get familiar with the general requested information. This will give you a sense of what they will look at. Also, if you have access to past exams, go get them and review all past violations or recommendations because this will be one of the first things they will look at to see if you have corrected these past deficiencies.

Get with the department managers and explain that you are the liason between the FDIC and the bank but that you have to have their utmost support and cooperation during this time.

Good luck and we are always here to support you in a crunch when the time comes, if nothing else for moral support..just remember you can do this and once it's over you will be a seasoned vet!

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#142560 - 12/22/03 10:52 PM Re: FDIC EXAM
Inquisitor / Sommelier Omega Offline
Diamond Poster
Inquisitor / Sommelier Omega
Joined: Aug 2003
Posts: 1,357
A Grant Wood painting.
If your boss expects you to turn a "3" into a "1" in one quarter, the exam is the least of your worries. Get your resume out!

Use you state organization. Depending on the examination date, schedule to attend a school if possible. You can not learn IT all - IT is a moving target. Pick a piece at a time and get familiar with it. Use the Alhpabet Soup. Use your auditor if possible. Use BOL.
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The opinions expressed are what you can expect for the price paid.

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#142561 - 12/23/03 01:36 PM Re: FDIC EXAM
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Having gone through a recent FDIC exam I recommend reviewing all mortgage loan for proper flood determinations and flood insurance. This is a HOT topic and it would be better to have it fixed prior to the exam. Another hot topic is HMDA if you are a reportable bank. Do the best you can with the 'hot spots' and take the examiner's advice on anything they find. It's not just you - it's the entire bank and the board of directors. You are not alone in this.
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#142562 - 12/23/03 01:43 PM Re: FDIC EXAM
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
Plan to be dominated. I agree with all the others.

Besides compliance, look for exam management. Make sure that the phones in the conference room are programmed to say FDIC, OCC, etc., and remind everyone to find out who is calling before answering questions. Use yourself (or audit), as the main contact. Don’t have the examiners talking to a junior level anyone who may not have a good overall knowledge of what the bank is doing.

Don’t lie of try to show off to an examiner, have them trust you and what you say. Visit the examiners on an hourly basis to ask if they need anything, or need a question answered! If you can do the legwork for them, there might be less written up or discussed with senior management.

Update management if possible during the exam so they do not have surprises. During the exam, document every step from introduction to close. This will be a good source for next year. Good luck.
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#142563 - 12/23/03 07:20 PM Re: FDIC EXAM
yy2say Offline
Gold Star
yy2say
Joined: Apr 2002
Posts: 279
PA
We just completed our FDIC examination and it worked out well ...yes Virginia, there is a Santa Claus!!!! I've only been here since the middle of August and they were on site November 3rd!!! You have hope!

I suggest going to the FDIC website and familiarizing yourself with the new compliance procedures. Concentrate really hard on Compliance Management. If you don't have a real good plan now, start preparing one. Gather the troops together and assign duties. You can't do it alone. I found the FDIC to be very helpful. They want to make sure that senior management and the board are supportive of your efforts and that folks throughout the bank are accountable for compliance in each of their areas.

If you are interested in some advice offline, please send me an email at ktoscano@unitedbank.net
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#142564 - 12/26/03 08:25 PM Re: FDIC EXAM
Data Offline
100 Club
Data
Joined: Oct 2002
Posts: 226
Houston
You can get through it, I just did. We formed a task force to meet every Thursday morning to discuss the exam. I made a folder for every page of the document request, labeled it and made a copy for myself of all the folders. Next, find your last exam and carry it with you everywhere. Look at the violations from the previous exam and personally check to see if they have been corrected through monitoring and training. Then ask the big questions to everyone you can. Does anyone know of anything that I should be aware of? The examiners want to know 1> did you fix what was broken on the last exam 2> Does your managment support you 3> How are you fixing technical mistakes. It is up to you. The examiners goals are to make the exam a partnership.
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