Bulletin from other regional office
Posted By: Banker Sue
Bulletin from other regional office - 02/10/06 08:37 PM
When a bulletin is issued by a regional office from your regulator do you abide by it?
For example the FDIC Chicago Regional office issued a bulletin regarding real estate taxes and a HUD settlement statement. My banks regional office is in Atlanta. Do we implement the changes based on this bulletin?
Posted By: flaire
Re: Bulletin from other regional office - 02/11/06 05:04 AM
Why would you even check bulletins from other regional offices?
Follow the guidance from your regional office. If you have a question on the applicability of something, call them for clarification.
Posted By: Elwood P. Dowd
Re: Bulletin from other regional office - 02/11/06 12:40 PM
Bulletins from regional offices are generally informal communications; i.e. you generally do not have to "comply" with a bulletin. However, without having read the one you are referring to, it appears to be addressing a federal legal requirement, perhaps something that the Chicago office has noticed that a number of banks are doing incorrectly. If that's the case, there should not be varying opinions between regional offices.
Call your regional office, provide them with a copy and see if they agree with what it says.
Posted By: rlcarey
Re: Bulletin from other regional office - 02/11/06 03:06 PM
Quote:
If that's the case, there should not be varying opinions between regional offices.
And what Utopian world did you wake up in this morning? 
After all, it was the Chicago office that started the whole thing about the necessity to disclose hazard insurance as a POC on refinances and I also believe they originally muddied the waters on what was a refinance under HMDA.
Posted By: SMQ, CRCM
Re: Bulletin from other regional office - 02/11/06 04:37 PM
Wasn't it the FDIC KC office that started the whole temp financing issue?
Posted By: rlcarey
Re: Bulletin from other regional office - 02/11/06 05:25 PM
Could be - but you see my point.
Posted By: Elwood P. Dowd
Re: Bulletin from other regional office - 02/11/06 05:45 PM
I would want to read it before I would reach the conclusion that it represented a rogue opinion, but perhaps my operative phrase was "should not be"?
In any case, the advice is unchanged, "Call your regional office..."
Posted By: David Dickinson
Re: Bulletin from other regional office - 02/11/06 06:18 PM
Reading info. from other Regional Offices (RO) is very beneficial. For instance, the St. Louis FRB is the leader when it comes to HMDA. They have a Q&A posted on their web site and I find their field examiners to be the most knowledgeable on Reg C. The Dallas FRB has been a leader on CRA - putting out the CRA grids, etc.
You only hurt yourself if you refuse to review materials from other RO's.
Posted By: rlcarey
Re: Bulletin from other regional office - 02/11/06 06:43 PM
Don't get me wrong. I'm not really saying to ignore them and some regional offices do put out some really good information. But when they start dealing with fringe issues that are gray or have been historically treated a certain way by the banking industry - you cannot tell me that it does not sometimes result in regional enforcement differences within and between agencies.
Posted By: Elwood P. Dowd
Re: Bulletin from other regional office - 02/11/06 06:54 PM
Quote:
...you cannot tell me that it does not sometimes result in regional enforcement differences within and between agencies
Unfortunately, Randy, I think David and I would stipulate to that. I can identify enforcement differences between field offices in the same region pretty readily.
Posted By: David Dickinson
Re: Bulletin from other regional office - 02/12/06 12:27 AM
Yep. Sometimes I'll have a banker call me and say "we got cited for XYZ" and I'll say "you must be FDIC regulated by the ABC Regional Office". All because of regional or, like Ken said, field office opinions.
However, it's still good to receive bulletins from the various offices. That way we all can stay as current as possible. I also think the regulatory world is (or should be) getting smaller as they compare notes with one another.
Posted By: Elwood P. Dowd
Re: Bulletin from other regional office - 02/12/06 10:38 AM
Quote:
I also think the regulatory world is (or should be) getting smaller as they compare notes with one another.
...and virtual connections between banks now make it possible to publicly illustrate that the discrepancies exist and draw them to the attention of regulatory personnel.
Posted By: waldensouth
Re: Bulletin from other regional office - 02/13/06 01:45 PM
Landline, The atlanta regional office also adheres to the guidelines in this memo. Our banks are in the Atlanta Region and this is something the examiners look for. When I first heard of this requirement, I wrote for clarification to Atlanta - they sent it to Washington and the official word from Washington DC was that we have to do it. They did hold off writing us up until the response from DC came back.
They began by telling us about the new guidelines and I fought it - but eventually lost.
Posted By: Trees
Re: Bulletin from other regional office - 02/14/06 02:24 PM
I agree with David. I've noticed that a number of the regional offices provide newsletters, etc. which I find a useful tool in trying to understand the federal perspective (read "do what I say not what I do"!). Our regional office is pitiful when compared to other regions in this regard so I go out to the websites of the other offices for guidance, esp. Philly and Chicago.
Posted By: Banker Sue
Re: Bulletin from other regional office - 02/14/06 02:41 PM
Does the Atlanta Regional Office have a website where bulletins they issue are available?
Posted By: David Dickinson
Re: Bulletin from other regional office - 02/14/06 08:04 PM
Atlanta what? FDIC, FRB?
Posted By: Banker Sue
Re: Bulletin from other regional office - 02/14/06 09:41 PM
Sorry thought I stated that in my original post....FDIC