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#1985427 - 12/29/14 07:41 PM From OCC to Fed exams
Anonymous
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We are considering changing from a National bank to a state bank under the Fed. Has anyone recently gone through this type of change, and if so, have any comments or suggestions with regards to the S&S exams?

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#1985436 - 12/29/14 08:31 PM Re: From OCC to Fed exams Anonymous
Susielou Offline
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Joined: Aug 2005
Posts: 337
Midwest
We will be doing this as well in 2015. I would appreciate any comments also.

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#1985463 - 12/29/14 09:23 PM Re: From OCC to Fed exams Anonymous
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
From a broad brush standpoint: Anytime I've seen one of our clients change charters, it will be one of the most thorough exams you'll ever have. There seems to be a "we'll show you how tough we are" mentality that goes along with these.

I also personally went through one of these (FDIC to FRB) when I was a loan officer/compliance officer. Doesn't mean you should change charters, just warning you to be ready for it.
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http://www.bankerscompliance.com

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#1985473 - 12/29/14 10:02 PM Re: From OCC to Fed exams Anonymous
Anonymous
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OP here. Thanks David. I guessed the exam to approve the conversion would be tough. I have been with this bank for over 17 years and we have been regulated by the OCC the entire time. We have a great relationship with our current regulators. The thought of changing charters makes my blood pressure go up! I was just informed of this today, so I have not been able to do much research on the differences in exams. As the person in charge of Compliance, my brain is going 90 to nothing right now!

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#1985507 - 12/30/14 01:19 PM Re: From OCC to Fed exams Anonymous
Anonymous
Unregistered

I have heard the FRB is tougher on compliance than the OCC. Just curious, why does management want to switch charters.

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#1985564 - 12/30/14 04:20 PM Re: From OCC to Fed exams Anonymous
Anonymous
Unregistered

Without any formal discussion regarding the pro's and con's of switching, my guess is cost savings would be one of them. I'm sure there are other reasons I am just not aware of yet.

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#1985700 - 12/30/14 10:03 PM Re: From OCC to Fed exams Anonymous
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
With a brush the same width as David's: I'm repeatedly told that the Fed has a more consultative approach; i.e. they are more interested in helping a bank do things correctly than in saying "gotcha" and doing the noodle dance in the lobby. The thorough exam he promised should be expected, they are trying set a benchmark and see if they wish you had stayed with your previous regulator.
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#1986113 - 01/02/15 08:20 PM Re: From OCC to Fed exams Anonymous
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Fed's are tough but I doubt they are worse than any others these days. They all want to shine and they are all in competition with cfpb. They have been fair and we have received technical versus flaming violations for one offs. If they tell you to do something in a report be sure you have done it exactly as they want it done. No corner cutting.

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#1987349 - 01/08/15 05:23 PM Re: From OCC to Fed exams Anonymous
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
I have worked with Banks that were OTS, then OCC and have now switched to FDIC. The two that switched to FDIC simply didn't want to deal with the OCC. ha.

Also, those two that switched to FDIC now get their S&S exam from the FDIC and they get an exam from the state banking department, rather than just one OCC exam.

IMO, it is easier to handle one regulator. The two are never on the same page and they provide conflicting information, guidance and findings.
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#1987424 - 01/08/15 08:06 PM Re: From OCC to Fed exams Anonymous
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,450
Pulling people out of the ditc...
my experience is that the OCC has what they deem "critical", and the FDIC and FRB have their own hit lists. joint FDIC/FRB this year, the FRB side was highly focused on IT risk and controls in place, while FDIC was all about compliance risk, fraud, and AML (including pro-active detection).

I have found the FDIC/FRB easier to work with simply that they say "here is what we need" and give you time to gather, then when you pass it to them they schedule time to discuss questions, etc. OCC were known to hover...walk in to your office, hand you a request, then sit and await you to gather the information...then any time they had a question just pop in and ask, never thinking they could wait and ask like 5 questions at one time toward the end of the day...
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#1987461 - 01/08/15 09:52 PM Re: From OCC to Fed exams Anonymous
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I'll second Ken's comments. We have about 600 bank clients - primarily FDIC as there are more FDIC charters. Stereotypically, the OCC is the hardest on micro-managing banks and sticklers on some pretty small compliance things. The FRB is the most "consultant" minded wanting to help banks get things right.

If this holds true for your OCC to FRB change, you should see some relief in the style of exam. Good luck!
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David Dickinson
http://www.bankerscompliance.com

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