I heard the same thing from my examiner (FDIC) about 18 months ago. "It looks more like you're monitoring..."
Anyway, after that experience, I bought a resource from Sheshunoff (Regulatory Compliance Audit Program), and I've been working with that. I've recently been cross-checking information in those questionnaires against the FDIC's 2006 examination manual. It seems to work for us - $640 million 2-bank holding company.
Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."