Is there a list out there for the hot buttons for examiners?

Fair lending
BSA
Patriot Act
Compliance risk assessment
to name a few...

GLB Act
Flood

We have the FDIC headed our way in a week for Safety and Soundness.. any last minute thoughts?

go on vacation.

My thoughts exactly!!!

Better be well prepared for Bank Secrecy/CIP and Information Technology.

We have the FDIC headed our way in a week for Safety and Soundness.. any last minute thoughts?

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Yes, it's too late. Be real nice - take your hits - act humble - hang on their every word - give them what they do not initially ask for (quickly) - all cards need to be on the table - the FDIC is lot more friendly and helpful, versus the past - thank God. Of course, unless they perceive you as a potential Camels 3-5 - if that's the case, going on vacation would work pretty well.

Might want to be aware of where you are on any issues noted in your last exam.

Have an up to date phone book available. I have found they spend quite abit of time looking through phone books for restaurants, etc. So you might have some suggestions on cheap eating places, and even cheaper places of local interest so they have something to do at night.

That's the truth Don!

FYI - for safety and soundness, make absolutely sure that you understand the concept of an "impaired" loan and have some monitoring process in place to determine if it applies to your portfolio.

From a regulator's perspective, here's what's on our minds:

[list]

BSA/Anti money laundering programs

USA PATRIOT Act compliance (CIP, foreign accounts, info sharing, etc.)

Predatory, abusive, or unfair & deceptive lending practices

FDPA compliance

RESPA Section 8 (kick backs or unsubstantiated fees passed on to the customer)

Overall compliance risk assessment/management programs

New products/ventures

We may not hit all of these every time, but over time, we will. Hope this helps. AR.

AnonRegulator: Can you define "FDPA" for me? Is that the Flood Disaster Protection Act"?

David,
I am pretty sure the reference is to the Flood Disaster Protection Act.

"Impaired Loan" definition
Thanks

FDPA is, in fact, the Flood Disaster Protection Act. Sorry for the jargon. AR.

Examiners recently looked at appraisal standards and RESPA, specifically, required providers and relationships.

Our FDIC compliance/cra exam was due for the third quarter of last year. Has anyone heard of them being late by several months? The President asks me almost daily if I have heard anything and I assure him that he will know before me.....but he keeps asking.

Yes, it has happened to us in the past. Don't worry - you are still on their radar!!!

Let's talk CRA. I thought they HAD TO BEGIN THE EXAM before the federally mandated date. Are you sure you had missed the exam date last year? Do you know your agencies timeframes (absolute drop-dead dates)? For example, I believe for FDIC small bank with a Sat. can go five years (BUT NOT A DAY LONGER) between the new start date and the date of the previous CRA exam date. For us it has been approx. 4 years and 7 months since the date of the last CRA exam and FDIC told us they HAVE to start our next one by August 1, 2004. They always seem to be scrambling to get these done under the wire........My last regulator was the Fed and also they seemed to be racing to meet those deadlines......

All comments welcome!

Re: the start date for small bank CRA exams...What the Gramm Leach Bliley Act mandated was that for small banks last rated Satisfactory, their next CRA exam may not begin any SOONER than 48 months from the last CRA exam. For small banks last rated Outstanding, the next exam may not begin any sooner than 60 months from the last CRA exam. GLBA was silent on a drop dead date by which these exams must be started, although at least one federal regulator has implemented an 18 month window after those dates in which the exams must be started.

The whole point of the GLBA provision was to provide some regulatory relief to the small banks. AR.