We've been hearing for months about the new FDIC compliance exam procedures - well the FIL introducing them was just sent today. The FIL contains an attachment of the first couple of introductory chapters about the risk-based approach and about sound compliance management. They say the complete exam procedures will be available on their website in June, so that only gives them 10 more days. More info here.

I received the questionnaire yesterday for the new exam procedures. We will be having an exam by the FDIC in August. Very thorough and they will be interviewing a myriad of employees from tellers to the CEO.

Could Mary Beth post the new FDIC questionnaire on BOL? It would be great to get a preview.

I had a PM from someone requesting this so I asked the examiner and just got his reply. He said it's all right to share. Mary Beth?

Yes they even mentioned tellers. I may sit in on the interviews if I like and I can even choose who they talk to.

Magic and I were at a conference in Florida eariler this year and heard the FDIC's senior compliance person from Atlanta describe the new process. While it sounds like "same old, same old" in some respects, FDIC supervised banks should take it seriously.

Their internal audit/examination techniques should be revised in a reflective fashion; i.e. they should interview employees too. Consider, the first time you were interviewed for a newspaper article or TV spot, how did you sound? Employees need to be comfortable with the information, but they need to be comfortable with the process too.

Examiners are trained on how to interview bank personnel. Bank personnel should be trained on how to be interviewed.

Re: FDIC new exam procedures -- how does this compare with the Fed's current procedures for exams? Did Fed already make a similar change?

Ken - do you have any resources that might be helpful in how to do this?

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Could Mary Beth post the new FDIC questionnaire on BOL? It would be great to get a preview.

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It's up! All 20 pages of it. Yikes.

Thanks to Al Miller for sending it.

You can get it in PDF or Word .doc format on the Banker Tools page.

Thanks MB and Al.

I am working on getting the info together in response to the document request linked to above for our FDIC compliance exam starting July 14th. I am somewhat confused about the wording diference between item 8 and 9 on page 8 (Truth in Savings section).

Item 9 asks for statements for each type of consumer account while item 8 asks for statements for each type of interest bearing account which incurred maintenance. My question may seem basic, if so, I appologize ahead of time. I have several years of experience in compliance, but it is almost exclusive in loan compliance or I should say non deposit related. The bank I am at now does not have a strong deposit side compliance officer and I am being asked if FDIC really wants copies of commercial account statements even though this is under TIS section. Our examiner is out of the office until Monday which is the day he is expecting our info.

What does everyone else think? Should we copy commercial account statements as well. My operations officer says it will require substantial time to research and find accounts which actually have been maintenanced.

Since these questions are in the TIS section, I would limit the request to accounts covered under the regulation. If they want more, they will ask.

Thanks for posting on the BOL. Our exam is in late July.

I assume each field office has control over the check boxes on the CIDR as to whether they want the individual items sent or held. Is that a correct assumption?

Also, another new acronym for us to pronounce - CIDR (Compliance Information and Documentation Request) - I'm going with pronouncing it as "Cider" as in "We just got the cider from the FDIC."

We have our exam the week after yours starts. I would be curious as to how it goes with the new CIDR and all.
If you wouldn't mind sending me a PM with any feedback, I would greatly appreciate it.
This is my first exam, and am somewhat tentative about how this will all go.

P.S. They didn't send us this new CIDR so I am thinking that we are still working off the old one they sent several weeks ago.

Thanks,
Bean

I talked on the phone with the FDIC and we went through all items, deleted some, etc. We do not have consumer leases and that section was removed. He indicated which items to send and to hold, but he also stated that if I was uncomfortable about forwarding items to let him know and we would retain here for his review when they arrive.

Cider...good. The Cider is far reaching into bank's policies, practices, etc. Do any of the questions/requests have a more sour taste than others to our BOL compliance folks? Has the Cider been an impetus to change any of your compliance program?

Severeral of you have mentioned that the FDIC will interview a myriad of employees from tellers to the CEO. Where do you see this or know this. I am looking at the Questionnaire and it has a sheet for the bank to list the contact person for each major product or dept. so I would think you can control who they talk to. We have always given them a sheet early on and told them the name and number of the person they should speak to about a particular question or process and then we have always ensured that this person had the knowledge necessary to deal with them or we put the CO's name instead. We are a large bank and so much of our loan compliance is built into our system so if they were to ask a lender they might not know but I am not sure that is their intent. Just wondered why some of you are saying this????

I was told verbally by the examiner. He also stated that we could choose who he spoke with and even sit in on the interview.

I was told verbally as well about the interviews. He said they would speak to some members of the Board and Senior Management to determine if they understand the policy and procedures and who they think is responsible for doing what and then they would interview some staff members to determine if they understood what the polices and procedures were and in particular what did Senior Management expect of them. My understanding was I would give the names of the staff to be interviewed to the examiner.

The examiner stated the purpose of the interview process was to identify potential red flags. If they found any than they would sample account records to see if deficiencies existed.

One thing I forgot to mention that they asked for. We have contacted our flood determination companies and requested a list from each on loans that are in a special flood hazard area. This is to be provided to the examiner and has been amazingly easy to obtain.

I have looked at the new FDIC Questionnaire and while it appears to require more paper to give to the FDIC, I think it is something we can gather and get but wonder why they want to see things like the Pricing and Credit Committee minutes and Loan quality control reviews. This appears to be Safety and Soundness, not compliance. Also the retention of having to keep all pre-testing and post-testing data of any new product seems like a lot. And then having to match up each loan product made by month with the denials for that product per month seems too burdensome. Maybe when someone has an exam in the near future, they can enlighten us on why they needed certain things.