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#174010 - 03/26/04 06:08 PM Hot topics for examiner scrutiny
Anonymous
Unregistered

Is there a list out there for the hot buttons for examiners?

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General Discussion
#174011 - 03/26/04 06:13 PM Re: Hot topics for examiner scrutiny
DeeQ Offline
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DeeQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
Fair lending
BSA
Patriot Act
Compliance risk assessment
to name a few...
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Get your facts first, then you can distort them as you please. - Mark Twain

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#174012 - 03/26/04 07:56 PM Re: Hot topics for examiner scrutiny
RR Joker Offline
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RR Joker
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The Swamp
GLB Act
Flood
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#174013 - 03/26/04 08:07 PM Re: Hot topics for examiner scrutiny
K8T Offline
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K8T
Joined: Sep 2003
Posts: 196
I have fallen down the rabbit ...
We have the FDIC headed our way in a week for Safety and Soundness.. any last minute thoughts?
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Some days, it is all a mystery to me.

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#174014 - 03/26/04 08:09 PM Re: Hot topics for examiner scrutiny
Anonymous
Unregistered

go on vacation.

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#174015 - 03/26/04 08:49 PM Re: Hot topics for examiner scrutiny
SHORT STUFF Offline
Member
SHORT STUFF
Joined: Feb 2004
Posts: 67
WISCONSIN
My thoughts exactly!!!

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#174016 - 03/26/04 08:53 PM Re: Hot topics for examiner scrutiny
BankerMama Offline
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BankerMama
Joined: Jun 2001
Posts: 1,543
Better be well prepared for Bank Secrecy/CIP and Information Technology.

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#174017 - 03/26/04 08:58 PM Re: Hot topics for examiner scrutiny
Paragon Offline
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Paragon
Joined: Dec 2003
Posts: 2,164
We have the FDIC headed our way in a week for Safety and Soundness.. any last minute thoughts?




Yes, it's too late. Be real nice - take your hits - act humble - hang on their every word - give them what they do not initially ask for (quickly) - all cards need to be on the table - the FDIC is lot more friendly and helpful, versus the past - thank God. Of course, unless they perceive you as a potential Camels 3-5 - if that's the case, going on vacation would work pretty well.

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#174018 - 03/26/04 08:58 PM Re: Hot topics for examiner scrutiny
DogLover Offline
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DogLover
Joined: Aug 2003
Posts: 146
Sunny Florida
Might want to be aware of where you are on any issues noted in your last exam.

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#174019 - 03/26/04 09:13 PM Re: Hot topics for examiner scrutiny
Pale Rider Offline
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under the Lone Star
Have an up to date phone book available. I have found they spend quite abit of time looking through phone books for restaurants, etc. So you might have some suggestions on cheap eating places, and even cheaper places of local interest so they have something to do at night.
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#174020 - 03/29/04 05:42 PM Re: Hot topics for examiner scrutiny
BankerMama Offline
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BankerMama
Joined: Jun 2001
Posts: 1,543
That's the truth Don!

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#174021 - 03/29/04 07:04 PM Re: Hot topics for examiner scrutiny
beaten blind Offline
Gold Star
Joined: Oct 2003
Posts: 473
the Bat Cave
FYI - for safety and soundness, make absolutely sure that you understand the concept of an "impaired" loan and have some monitoring process in place to determine if it applies to your portfolio.

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#174022 - 03/29/04 07:23 PM Re: Hot topics for examiner scrutiny
AnonRegulator Offline
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AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
From a regulator's perspective, here's what's on our minds:

[list]
  • BSA/Anti money laundering programs
  • USA PATRIOT Act compliance (CIP, foreign accounts, info sharing, etc.)
  • Predatory, abusive, or unfair & deceptive lending practices
  • FDPA compliance
  • RESPA Section 8 (kick backs or unsubstantiated fees passed on to the customer)
  • Overall compliance risk assessment/management programs
  • New products/ventures

    We may not hit all of these every time, but over time, we will. Hope this helps. AR.

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    #174023 - 03/29/04 08:49 PM Re: Hot topics for examiner scrutiny
    David Dickinson Offline
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    David Dickinson
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    Central City, NE
    AnonRegulator: Can you define "FDPA" for me? Is that the Flood Disaster Protection Act"?
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    http://www.bankerscompliance.com

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    #174024 - 03/29/04 08:51 PM Re: Hot topics for examiner scrutiny
    DeeQ Offline
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    Turnpike Exit 10
    David,
    I am pretty sure the reference is to the Flood Disaster Protection Act.
    _________________________
    Get your facts first, then you can distort them as you please. - Mark Twain

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    #174025 - 03/29/04 08:54 PM Re: Hot topics for examiner scrutiny
    Patsy Cline Offline
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    Patsy Cline
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    On the road...
    Quote:

    AnonRegulator: Can you define "FDPA" for me? Is that the Flood Disaster Protection Act"?




    _________________________
    Michelle CRCM

    "What would you attempt to do if you knew you could not fail?" ~ unknown


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    #174026 - 03/29/04 10:01 PM Re: Hot topics for examiner scrutiny
    Anonymous
    Unregistered

    "Impaired Loan" definition
    Thanks

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    #174027 - 03/30/04 02:29 PM Re: Hot topics for examiner scrutiny
    AnonRegulator Offline
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    AnonRegulator
    Joined: Mar 2002
    Posts: 451
    Everywhere, USA
    FDPA is, in fact, the Flood Disaster Protection Act. Sorry for the jargon. AR.

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    #174028 - 03/30/04 07:18 PM Re: Hot topics for examiner scrutiny
    Anonymous
    Unregistered

    Examiners recently looked at appraisal standards and RESPA, specifically, required providers and relationships.

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    #174029 - 03/30/04 08:13 PM Re: Hot topics for examiner scrutiny
    MackenzieS Offline
    Diamond Poster
    MackenzieS
    Joined: Jul 2002
    Posts: 1,722
    Oklahoma
    Our FDIC compliance/cra exam was due for the third quarter of last year. Has anyone heard of them being late by several months? The President asks me almost daily if I have heard anything and I assure him that he will know before me.....but he keeps asking.

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    #174030 - 03/30/04 10:07 PM Re: Hot topics for examiner scrutiny
    JSD Offline
    Platinum Poster
    JSD
    Joined: Oct 2000
    Posts: 512
    USA
    Yes, it has happened to us in the past. Don't worry - you are still on their radar!!!

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    #174031 - 03/30/04 10:52 PM Re: Hot topics for examiner scrutiny
    Anonymous
    Unregistered

    Let's talk CRA. I thought they HAD TO BEGIN THE EXAM before the federally mandated date. Are you sure you had missed the exam date last year? Do you know your agencies timeframes (absolute drop-dead dates)? For example, I believe for FDIC small bank with a Sat. can go five years (BUT NOT A DAY LONGER) between the new start date and the date of the previous CRA exam date. For us it has been approx. 4 years and 7 months since the date of the last CRA exam and FDIC told us they HAVE to start our next one by August 1, 2004. They always seem to be scrambling to get these done under the wire........My last regulator was the Fed and also they seemed to be racing to meet those deadlines......

    All comments welcome!

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    #174032 - 03/30/04 11:08 PM Re: Hot topics for examiner scrutiny
    Andy_Z Offline
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    On the Net
    Quote:

    Our FDIC compliance/cra exam was due for the third quarter of last year. Has anyone heard of them being late by several months? The President asks me almost daily if I have heard anything and I assure him that he will know before me.....but he keeps asking.




    The good news is someone has a higher priority than you. But you might contact them just to verify the dates since you already know they'll be coming and you want to ensure they'll have space to work, etc.

    I find that good communication is very helpful in a marriage, and an exam.
    _________________________
    AndyZ CRCM
    My opinions are not necessarily my employers.
    R+R-R=R+R
    Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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    #174033 - 03/31/04 02:33 PM Re: Hot topics for examiner scrutiny
    AnonRegulator Offline
    Gold Star
    AnonRegulator
    Joined: Mar 2002
    Posts: 451
    Everywhere, USA
    Re: the start date for small bank CRA exams...What the Gramm Leach Bliley Act mandated was that for small banks last rated Satisfactory, their next CRA exam may not begin any SOONER than 48 months from the last CRA exam. For small banks last rated Outstanding, the next exam may not begin any sooner than 60 months from the last CRA exam. GLBA was silent on a drop dead date by which these exams must be started, although at least one federal regulator has implemented an 18 month window after those dates in which the exams must be started.

    The whole point of the GLBA provision was to provide some regulatory relief to the small banks. AR.

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    #174034 - 03/31/04 02:34 PM Re: Hot topics for examiner scrutiny
    Starky Offline
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    Starky
    Joined: Oct 2002
    Posts: 204
    Arkansas
    Quote:

    Our FDIC compliance/cra exam was due for the third quarter of last year. Has anyone heard of them being late by several months? The President asks me almost daily if I have heard anything and I assure him that he will know before me.....but he keeps asking.




    Our OCC exam was also scheduled for the 3rd quarter last year. They came to the bank and completed it this past February.

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