We completed a BSA exam recently. The examiner, in the exit meeting, gave the overall conditions of the bank as generally satisfactory, competent staff, independent review satisfactory, ensure annual training.....By and large, it appeared the bank did well.

During the board meeting, the examiner ripped the bank apart on BSA. He mentioned that 10% of one part was in error and 5% of another.....Then he spoke to them of repeated violations being cause for cease and dissist.

How can the two be so different....Is there any rebuttal that we can use......

The way I understand it, the examiner assigned to review BSA gives the exit interview and then the EIC goes over their work and writes the final report. Our EIC let us know that the examiner's report in the exit interview was preliminary and that he would be writing the final report to the BOD after he had reviewed her work. Maybe the examiner that reviewed your BSA program missed something that the EIC picked out in their review? Not sure about a rebuttal.

An examination team does no one any favors when it presents two faces in the exit interview and board presentation. When your bank merits a dressing-down at the board meeting, the exit interview should at least reflect some of the problems.

You should be able to discuss the apparent disconnect between the two sessions with the EIC to find out why the board was given such a negative picture.

If you are not satisfied with the EIC's explanation, a call to you ombudsman might also be in order.

I called the ombudsman once and never got a return call. To whom do you report the ombudsman?
We had that happen too but in other areas (not BSA). However, every portion of the exam that had an exit conference also had erroneous information presented and the Lead examiner and four of the staff had already had personality clashes with everyone they had spoken to from the CEO to the reception desk. We smiled and nodded and then called the guy in charge of the office and followed up with a letter. Their return visit (same examiners) had a very different face and attitude. Sometimes it's just little people with a little power.