I doubt a bank like that would let loan admin read the exam report, or even a summary of it.



However, I ditto Deekles and KB. There's nothing worse than a "know it all" new hire who goes around prefacing every sentence with, "At my old bank we..." Two times we had someone like that - a manager moving from another bank - and they proved impossible to train. They assumed they were there to set us straight. But look at your co-worker's and employer's perspective - if you are so great, why are you not still with your prior employer, right? I'd zip it for 6 months or a year, and then see how the next exam goes. If the exam goes off fine, then why appoint yourself your employer's regulator? Plan B: ask to leave your position to volunteer to become their compliance officer. Warning - that might result in termination.

I agree with a lot of what's been said here. However, I will say that in speaking with friends/past co-workers who have moved jobs recently from one bank to another (for various reasons) I'm shocked at what I hear goes on at other banks. Some of these banks are large and have the typical "we've been doing it this way for X years and no one has said anything" mentality. Working at a small new bank (1 branch 100 million assets), we're examined and audited with a fine tooth comb, if we sneeze, the Regulators will find it. But I think that some larger banks who are financially sound their exams are on another (higher) level and these things just aren't being found. (not speaking about all larger banks here and no offsense to any BOL posters banks )If there isn't a solid internal/external audit system, it won't be found either. So until an Examiner comes in with something to prove or happens upon something it might not be found. Unfortunately, it puts you in a difficult position. If you are sure you're correct, the best you can do is attempt to address it carefully and try not to come off like you know you're right, but more of a "my understanding of the regulation is...". You will probably not be well received, but its probably all you can do. In the meantime, make sure your resume is up to date. And prepare yourself for the possibility that the next exam might stumble on some of these things.



As far as the statement above, I definitely don't agree. There are many reasons for people to seek other employment, especially right now, bank closures, suspicion of bank closure or the simple fact that you want to advance your career. Just because someone switches jobs doesn't mean they aren't valuable and/or knowledgeable.

We have been down this road before, but you really can't throw all large banks in the same bucket. Some of the wildest things I see I see at smaller banks. I have worked at small, large and extremely large and some of the toughest compliance I have seen was at extremely large - where compliance actually had the power to stop a new product.

I also work with some small de novos who have a very strong compliance culture and set it up correctly from day 1, and with others same size same situation who say "prove I can't do that".

It all depends upon senior management.

That being said, coming in as the new kid on the block, not even in a compliance position, and telling them everything they are doing is wrong when it has passed muster up until now won't get you far. These things get political fast and you can find yourself out on the street.

There are ways to say things and make concerns known. Find out who has influence and try to work with those people. And if you feel you can't live with it find another position elsewhere. I've done that, but I was in a position where I would be held responsible by regulators.

Kathleen - I wasn't trying to throw all large banks in the same bucket and I tried to qualify my statement by saying some of these banks are larger and financially sound. I guess the point I was trying to make is that the larger the bank, it can be more of a "needle in the haystack" kind of thing and it may take longer for these types of things to get to the point that they get noticed by an exam. And when the bank is large and financially sound, it seems that maybe regulators aren't "digging" as deep as they are with de novos or with banks that are not doing as well financially. I've worked at large and small banks and credit unions and I agree that sometimes the smaller ones (banks and CU's) do some really crazy stuff.

As someone who has worked in positions that dealt very closely with compliance, audit and finance/accounting and worked directly with Federal Examiners during exams and is one of those people who came from a small de novo (100 million) to a larger institution (2 billion) I can’t believe the things the larger bank gets away with that we never could at the smaller bank. It’s hard coming in with fresh eyes and seeing things going on that shouldn’t be, but I also know I just better CYA and not make too many waves too early. In this economy I don’t want to be looking for a new job.

I for one am with KathleenB when I worked for a mega sure we were not always correct but when something was wrong it was corrected (although it may take some time).

The thought process was when small bank does somthing wrong and it is caught it is reparied, when the mega does the same (and caught)it is a front page article in the paper and a CMP.

Getting into this a bit late, but FWIW, my 2 cents. There are things different than at your former job. Some different things may be right, some may be wrong. To label all differences as wrong may not be giving credit to an alternate way of doing things may be a problem.

Experienced bankers worry most about new examiners reviewing the bank for the same reasons. If things are different than the last bank (the one they liked), they might cite it as an exception, even if it is correct. An experienced examiner might overlook the same issues as something minor in the overall scheme of things with a been there, done that philosophy.

Don't get lumped into the same category as a new bank examiner. Like others have said, learn and don't be overly critical. An error may be an error, but not all will be violations. Document, but don't put yourself into the position that management fears that you will go off the deep end and turn over all things you do not agree with to examiners, auditors and anyone else that will listen to you.

I agree with Southern Banker. Going to the examiners as your first course of action will blow everything way out of proportion - and not only will you lose credibility with your bank, you could lose credibility with the examiners as well. And the world of banking is VERY small in the scheme of things. Word gets around, and you don't want to be known as one who will go straight to the examiners with any issues you may find in the first month on the job. Good luck getting a job in banking again...

I've been out of the bank for a while and am just trying to catch up on BOL so forgive the late addition to this thread but...this is a joke, right?

Just look at how it reads:
A brand new hire walks into a bank and decides (s)he knows best but no one will listen so (s)he wants to call examiners in to set things straight? Seriously???? You weren't hired to do compliance. And it's none of your business how the company wants to run their business.

That said, I totally get that it can stick in your craw. If you don't want to do the job you were hired to do the way you are directed to do it, then the only choice you have is to find a different job.

By reading some of the responses in this thread, I can easily tell who has been in banking for a long time and doesn't like being questioned. But that's not the issue at hand.

As others have stated already, if you're sure something is wrong, you should alert Senior Management and document everything. Keep printed copies of all emails off site. If you do contact the regulators I can all but assure you that you will be looking for a new job, whether you’re right or wrong.

The best advice I could offer is to start looking for a new job and play ball until you can leave. After you secure you’re new position, if you still feel something is wrong, you can pick up the phone and call the regulators then.

find a different employer, problem solved.

and, it doesn't sound like you are qualified to make such a conclusion after being there for a month. what exactly is your position?

i am a compliance officer and there are many things that we do at our bank that i don't agree with. the only thing i can do is voice my opinion/concerns, document them and hope that it gets changed. ultimately, it is management and the board who will make the decision, good/bad/compliance or not.

I concur with these statements.