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#579949 - 07/06/06 03:08 PM Examination Interviews
peachtreekid Offline
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Joined: Jul 2006
Posts: 1
Georgia
Need feedback on limiting interviews with examiners (Fed) on one-on-one basis. Does anyone have experience?
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nheard

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#579950 - 07/06/06 03:21 PM Re: Examination Interviews
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Management should discuss with them having someone with employees who are interviewed. Designate who that "someone" will be.

Unless it is a problem bank situation, that is generally fine.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#579951 - 07/06/06 04:16 PM Re: Examination Interviews
Creditcop Offline
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Creditcop
Joined: Sep 2002
Posts: 1,685
Indiana
I agree with Kaybee. Give them a contact person. However, I have seen examiners go to other employees and ask questions. It depends on the type of exam. If BSA is involved we had examiners calling our branches (without our knowledge) and asking questions. When they got different answers at different branches, we had a problem and we are in the process of fixing.

Sometimes you can't limit examiners contacts, they can be sneaky sometimes.

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#579952 - 07/07/06 02:52 PM Re: Examination Interviews
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
PTK: We set up an initial meeting with the EIC where we went over intros, accomodations, parking, and, oh yea, please meet our Risk Manager. We addressed it as an audit issue. The Risk Manager made sure that any exceptions were addressed and any paper requiring a response was tracked in our audit process.

Our RM was basically assigned to examiner traffic and it worked out well. He herded them towards the right people and had a heads up on what they were looking at or questioning.

Good luck to you!

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#579953 - 07/07/06 03:47 PM Re: Examination Interviews
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Creditcop is correct that the examiners, particularly for BSA (to test knowledge and training) will call employees and drop in to branches. However, for other set discussions they are amenable to having someone there. You do want at least 2 sets of ears to hear the conversations AND you want someone keeping track centrally.

I have only seen examiners insist on one -on-one meetings (outside of BSA type of spot checks) in a problem bank situation where they were assessing management capabilities. That is a whole other ball game.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#579954 - 07/10/06 09:25 PM Re: Examination Interviews
PJ Offline
100 Club
Joined: Sep 2005
Posts: 115
I agree that communicating with your EIC will generally get you the desired result -- but also communicate your expectations to your staff. That way if an examiner goes to someone one-on-one, they will know to call in their supervisor, or someone designated by you.

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#579955 - 07/13/06 10:33 AM Re: Examination Interviews
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
PJ's got a good point too. Given that providing examiners with a list of appropriate contact personnel is both helpful and prudent, you simply cannot control who examiners talk to.

All employees should understand what the purpose of the examination is; that the people involved are examiners, not auditors; and that involving their supervisor in conversations with examiners is expected. Employees should emphatically be told that "I don't know" is an acceptable answer and far preferable to a guess. Auditors who rely heavily on interviews contribute to helping employees develop the necessary skill set.

We had an employee, fairly described as a PITA, who gave an answer about our processes that was blatantly wrong. We spent the rest of the exam trying to kill the issue and had to repeatedly emphasize that she was not on the list of knowledgeable employees we had given them, the answer was simply incorrect, and her answer reflected nothing more than her unending need for attention. In the CYA move of all time, the examiner raised the issue in the exit conference and then noted that there was no evidence that the statement was correct and the bank had denied it.

It turned out okay, but it was a huge waste of both the bank's and the examiners' time.

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