Rather than muck up the thread, I thought I'd bring Dan's comment from the 'Flood Insurance no longer needed' thread here for any/all to react.


Well, if the desired effect was to strike fear into the hearts of compliance folk across the county, those examiners reading this are probably grinning ear to ear 'cause they've succeeded.

It's hard enough to play by rules that keep coming and coming. But when the rules are subject to constant re-interpretation that you're got to fend off, it just keeps making this job harder. It's starting to feel like a witch hunt instead of that examiner by-line of 'we're just here to help you'.

Who'd like the soapbox next?

Me, PLEASE!!!

"But when the rules are subject to constant re-interpretation "

Man did you hit the nail on the head. And OMG, if you point that out, you might as well shoot yourself. I'm too afraid to really say what's on my mind, but when I started this, back in the 90s, they really were there, as a partner to keep the banking system strong. Back in the day, I could have called anyone in the field office for guidance. I don't waste my time anymore. To ask something that requires an answer, (like most questions seem to do), is just plain futile. I'm starting to feel in compliance, like I do as a citizen...HELPLESS. I guess if we all just suck it up and adapt to what it truly is- an advesarial system - we'll be ok. (NOT)

Ooooo, I just realized this is Lending Compliance, not the Water Cooler. Let's see if the right to free speech still exists.

NEXT?????

To bring another thread here and paraphrase "There are still some good people left" by DSkittles.

Our bank is still pretty lucky in our group of examiners. I might be singing another tune come our next exam in a few months. I can still pick up the phone and get help pretty quickly.

Jeez - I hope I didn't just jinx myself!

I think the fact that there are 58 views (at the time of writing this) and only one response (in over two hours) tells a lot about how...

1) afraid many people are to voice their opinion - even in this day in age of susposed online anonymity and/or

2) busy we are that it's not even worth the time to vent because it wouldn't make a difference any way and/or

3) bitter we are about what our government has done to make such a mess of the whole thing.

If there is one thing in life I know without hesistation that I can always rely on...it's that our government will be there to make a bigger mess (rather than pick it up).

I feel a little better now...I think I'll go and get a manicure. :0)

I have to agree. Our last examination team (FDIC) were thorough and fair (for lack of a better term). I was able to call them subsequent to the exam to get further clarification on a few points. During the exam they even gave some useful feedback on the way we were handling certain areas.

This might not be the norm or an indication of future relationships, but I have to give them credit.

I am anxious to see what our exam expected next spring will bring. Generally our examiners have been helpful in answering questions and usually provide the answer I am expecting. I hope they haven't transferred into an "out to get you" type attitude.

Compliance definately isn't what it used to be. I haven't been in it nearly as long as many of you have been. But I do recall the days of when there was a rule change, it was written in a way that could be applied to the practices of most banks. Instead today, it is 1000 pages of garbage that makes no sense leaving the door open for the kind of mis-interpretation Truff eluded to above. All the rule changes are one thing, but if they are going to do these things, at least have them make sense. But who I am I to talk...I already submitted my resignation.

A recent EIC was very good, fair, and worked with us. this EIC was roundly critizied by his/her boss for doing so. I believe that the "examiner is your friend" attitude will go away for awhile and revert back to the previous adversarial attitude.

Generally, our compliance exams are all but a "non-issue". With all the changes and confusion, it will be somewhat interesting to see what next year's exam will bring. They do an off-site interim review on bank's our size, but I sent them what they wanted and haven't heard word one back from that. Not sure if that is good or bad, or if they haven't gotten around to looking at it yet, but it was 2-3 months back that they made the request.

S&S exams, on the other hand...we've were raked over the coals (mostly warranted) on CRE a couple years ago and they have taken a tough stance...but more recently, it's been way more congenial and fairly uneventful.