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#679573 - 02/05/07 03:43 PM Top 10 List
JSD Offline
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Joined: Oct 2000
Posts: 512
Where can you find the list of top compliance exceptions noted during exams that the Feds & FDIC publish? Thanks

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Lending Compliance
#679697 - 02/05/07 05:11 PM Re: Top 10 List JSD
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
The last several years I have taught on this topic for the ABA Conference. Each year I contact the regulatory agencies and ask them for this info. Most are reluctant to give this out and hence, we aren't seeing this information as readily as in years past. The regulators tell me that when they produce a "Top 10 list", they find that the field examiners seem to focus on these even more. Therefore, many agencies have stopped providing the information.

The FRB issues an annual report each year to congress. They don't list the violations in any order (1-10), but you can extract it. The OCC doesn't keep any statistics for their large banks, but I've been able to get it for their small banks. The FDIC also has sent me information.

For future reference, you can probably Google this (I have done so in the past). If you want to look back, visit the E-Newsletter Page of our Website and go to the "Archives". There you can see a brief description of each month's topics. You can scan the topics for "top viola tons". For instance, in June 2006, we ran an article on the "Top Violations of 2005". This was a consolidation of all 4 banking regulators.

Good luck.
David Dickinson

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#680159 - 02/05/07 09:30 PM Re: Top 10 List David Dickinson
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,159
Toano, VA
It's interesting that the agencies recognized the "violation of the month" problem and stopped giving their field examiners a checklist for a "witch hunt" exam. Maybe there's hope for them after all.

JSD- I can't tell you what's on the list, but I can describe the types of violations. Common violations will always include errors or oversights relating to:
- new or recently amended regulations
- transaction-specific regulations (as contrasted with process-specific or product-specific regs)
- hot button regulations receiving extraordinary attention by the agencies
...gone fishing.

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