Included in your job description

How many of us include writing comment letters in our job descriptions?

I ask because mine doesn't. In the past I would try to route my comment letters by key members of senior management. But as the 326 deadline nears, time for that is limited.

I'd feel more comfortable if I had that task in my job description and could just represent the bank without additional review, if necessary.

So Q2 - How many of you staff your requests to others prior to submission, or are your letters a group project to start with?

Andy,

Nope, comment letters are not part of my job description either.

I usually write the first draft and then it becomes a group effort to finalize.

Pat Field
First Arizona Savings

I write the draft of the comment letter, but have others who may be affected by proposed changes review and provide their comments. Writing comment letters is not part of my job description, but I belive it should be included.

Mine doesn't either, but it should be. I end up writing comment letter on not only compliance topics but also safety and soundness ones.

Before writing I try and solicit feedback from the affected groups - but its tough to get them to read the full proposal - so I end up pulling something together based on my understanding of how we do business and then circulate. Usually the Pres signs the letters - I just think that the regulators pay more attention to those letters.

My CIP letter went to the Pres today, coincidently - waiting for his feedback before I ship it off.

Thank you Andy, for bringing up my favorite soap box topic. Commenting SHOULD BE in your job description. Commenting is the difference between taking the offense and only running defense. Commenting is your opportunity (usually the only one) to make sure the regulation writers understand the process they are regulating. I speak as a former regulation writer.... Comments are the regulator's connection with reality. If you wonder whether comments are useful, just look at any regulation that you are having difficulty understanding or complying with. It is probably because the regulators didn't get enough comments.

I want everyone out there to comment to HUD on its RESPA proposal! If you don't know what to say, tune in on Sept 25 and we'll make it easy for you.

Comment letters are in my job description. But, whatever we write, we ask for suggestions and input from the business unit managers. Lucy's comments are right on, this trips my soapbox too! I view comment letters as your golden opportunity to make a difference; and if you choose to let that chance slide, then I think sometimes we don't like the results. One other thing that we do to try to make this as painless as possible for the business unit managers, is to advise them of the comment period when the proposal is issued, and then two or three times prior to the expiration date we remind them of the date. Sometimes, it even helps to set up a meeting (lunch, whatever) with them to get their thoughts.

I'm not really sure if it's in my job description, but I've written two. In each case I ran them past Senior Management who gave me free range. I was told that I am supposed to represent the company on such regulatory matters, and they seemed to trust me to do it appropriately.

Nope, not in my job description.

I would maintain that we should amend our job descriptions to include this. We should force ourselves to be more proactive and to get more bang for the buck as we read and interpret the proposals. If you've done all that and decided on what you do and don't like, writing it down and sending it is is but one small step for compliance, one giant leap for our industry. (The "thought 4 the day" thread is stuck in my mind.)

Absolutely! But then, you already know what I think.

Make a New Year's resolution (now) to get it in your job description and -- even more important -- write and send that letter!