Regulatory Examination Process



Similar documents
COMPLIANCE MANAGEMENT SYSTEM

Board Responsibility. A bank can outsource a task, but it cannot outsource the responsibility.

GENERAL INFORMATION AND INSTRUCTIONS

Office of Audits and Evaluations Report No. AUD The FDIC s Examination Process for Small Community Banks

BASIC EXAMINATION CONCEPTS AND GUIDELINES Section 1.1

PRIVACY IMPACT ASSESSMENT

Risk Profile and Scope Memorandum Template; Sample Risk Profile and Scope Memorandum

Risk Management Programme Guidelines

Federal Reserve System. Framework for Risk-Focused Supervision of Large Complex Institutions

Federal Regulatory Agencies Administrative Guidelines. Implementation of Interagency Programs for the Supervision of Technology Service Providers

Office of Inspector General

Supervisory Approach Section 100

HSBC FINANCE CORPORATION CHARTER OF THE RISK COMMITTEE

How To Write A Bank Deposit Insurance

Office of Inspector General

Report of Examination Page 1 Template; Sample Report of Examination ( Bank of Anytown )

Banking Regulation and Supervision Agency of Turkey (BRSA)

FINANCIAL INSTITUTION EXAMINER

Community Bank Risk-Focused Consumer Compliance Supervision Program

Office of Material Loss Reviews Report No. MLR Material Loss Review of Horizon Bank, Bellingham, Washington

September 26, 2002 Audit Report No Statistical CAMELS Offsite Rating Review Program for FDIC-Supervised Banks

March 26, 2003 Audit Report No FDIC Examiner Use of Work Performed by Independent Public Accountants (IPAs)

Asset Liability Management

II. Compliance Examinations - Compliance Management System. Compliance Management System. Introduction. Board of Directors and Management Oversight

The FDIC s Response to Bank Secrecy Act and Anti-Money Laundering Concerns Identified at FDIC-Supervised Institutions

Market and Liquidity Risk Assessment Overview. Federal Reserve System

Corporate Decision # July 12, 2005 August 2005

Federal Home Loan Bank Membership Version 1.0 March 2013

The Failure of Capital Corporate Federal Credit union

TITLE I SAFETY AND SOUNDNESS. Subtitle A Deposit Insurance Funds

COMPLIANCE MANAGEMENT SYSTEM

Board of Directors and Management Oversight

BOARD OF GOVERNORS FEDERAL RESERVE SYSTEM

REGULATORY COMPLIANCE SERVICES for Financial Institutions

Key learning points I

Office of Thrift Supervision. OMB FY 2009 Budget & Performance Plan

APPENDIX A NCUA S CAMEL RATING SYSTEM (CAMEL) 1

A Banker s Quick Reference Guide to CRA

May 2009 Report No. AUD Material Loss Review of Security Pacific Bank, Los Angeles, California AUDIT REPORT

Supervision and Regulation

Chapter 11. Economic Analysis of Banking Regulation

GENERAL INSTRUCTIONS DE NOVO APPLICATION FOR MEMBERSHIP IN THE FEDERAL HOME LOAN BANK OF ATLANTA APPLICATION SCHEDULES

WASHINGTON, D.C. SACRAMENTO, CALIFORNIA

FDIC Atlanta Region Regulatory Conference Call Commercial & Industrial Lending April 12, 2012

December 12, C.F. Muckenfuss, III Gibson, Dunn & Crutcher LLP 1050 Connecticut Avenue, N.W. Washington, DC

CFPB Consumer Laws and Regulations

Schwab Bank Savings. An FDIC-insured deposit feature for retirement plans

CREDIT RISK MANAGEMENT

Privacy Impact Assessment of the CHAT Suite of Analysis Tools

Interest-Rate Risk Management Section

TAKING ADVANTAGE OF THE INSURANCE PROVISIONS IN THE GRAMM-LEACH-BLILEY ACT

STATEMENT OF THE FEDERAL DEPOSIT INSURANCE CORPORATION RICHARD A. BROWN CHIEF ECONOMIST

FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. CALIFORNIA DEPARTMENT OF FINANCIAL INSTITUTIONS SAN FRANCISCO, CALIFORNIA

Central Bank of The Bahamas Consultation Paper PU Draft Guidelines for the Management of Interest Rate Risk

NATIONAL CREDIT UNION ADMINISTRATION OFFICE OF INSPECTOR GENERAL

Validating Third Party Software Erica M. Torres, CRCM

#15 SMALL TRUST DEPARTMENT (Total Fiduciary Assets Less Than $100MM)

Statement by. Preston Martin. Vice Chairman, Board of Governors of the Federal Reserve System. before the

Revised May Corporate Governance Guideline

Small Institutions Examination Procedures and Sample Format for Public Disclosure of Examination Results

Office of the Comptroller of the Currency. Washington, DC Director s Toolkit. October (reprint, September 2013)

FEDERAL RESERVE SYSTEM. PacWest Bancorp Los Angeles, California. CapGen Capital Group II LP New York, New York

GAO. FEDERAL RESERVE BOARD Merger Process Needs Guidelines for Community Reinvestment Issues

CFPB Examination Procedures

1. promoting an efficient and effective financial system that adequately finances economic growth, and

OCC 98-3 OCC BULLETIN

The Importance of Understanding and Developing a CRA

Outsourcing Risk Guidance Note for Banks

Application for a Banking Authority Foreign Bank Branches Prudential Statement J2

RISK MANAGEMENT OVERVIEW 2011 RISK CONFERENCE SPONSORED BY THE FEDERAL RESERVE BANK OF CHICAGO AND DEPAUL UNIVERSITY

Risk Management. Mike Loughlin Senior Executive Vice President Chief Risk Officer. May 22, Wells Fargo & Company. All rights reserved.

APEC Policy Dialogue on Deposit Insurance: Trigger Mechanisms for Early Intervention

Risk Management. Credit Risk Management

Federal Reserve Bank Surveillance and Early Warning System

State Farm Bank, F.S.B.

Business Combinations. Comptroller s Licensing Manual

Office of Material Loss Reviews Report No. MLR Material Loss Review of RockBridge Commercial Bank, Atlanta, Georgia

Federal Branches and Agencies Supervision

BOARD OF DIRECTORS RESPONSIBILITIES FOR COMPLIANCE MANAGEMENT SYSTEMS

Basel Committee on Banking Supervision. Consolidated KYC Risk Management

Bank. Directors. F e d e r a l R e s e r v e B a n k of K a n s a s C i t y Division of Supervision and Risk Management

Foreword 28. Introduction 30. Structure of the banking system 31. Why banking stability is important 33. Licensing requirements for banks 34

Fair Lending and HMDA Compliance

Basel II, Pillar 3 Disclosure for Sun Life Financial Trust Inc.

Asset Liability Management for Insurance Companies

Striving for Perfection Dedicated to Excellence

Management Accounting

Information Technology Risk

GUIDANCE FOR MANAGING THIRD-PARTY RISK

Statement of Principles

People s United Financial, Inc.

CONSULTATION PAPER Proposed Prudential Risk-based Supervisory Framework for Insurers

NORTHERN TRUST CORPORATION BUSINESS RISK COMMITTEE CHARTER

Capital adequacy ratios for banks - simplified explanation and

BOARD OF GOVERNORS FEDERAL RESERVE SYSTEM

Through decades of experience

Risk governance: OCC codifies risk standards, paving the way for increased enforcement actions

Last Updated: February 2014

GUIDELINES FOR THE MANAGEMENT OF OPERATIONAL RISK FOR CREDIT UNIONS

Mortgage Banker Examination Overview

Transcription:

Regulatory Examination Process 1

Objective To provide general examination-related concepts and terms used by regulators 2

Regulators Most common regulatory agencies that will interact with your bank: FDIC Insures deposits and conducts examinations State Banking Agency Issues charters and conducts examinations The Federal Reserve Regulates bank s holding company 3

Examination Process The bank receives a request letter for various schedules and information such as: Balance sheet and income statement Written policies and procedures Latest board packet Board minutes Reports (Past Due, Audits, Problem Loans etc.) 4

Examination Process Continued Off-Site review of information requested from the bank and gathered from other sources On-Site review which includes in-depth discussions with management Exit Meeting where findings and ratings are presented to management Examiners may also meet with the board to discuss findings The FDIC issues a written Report of Examination 5

Examination Ratings Reflects the condition of the bank or areas assessed and are assigned to an institution at each examination Composite Rating: overall rating based on the essential component factors for Safety and Soundness ( CAMELS ) and the bank s CMS for Compliance Component Ratings: specific to the Safety and Soundness CAMELS components 6

Rating Scale Composite and component ratings are each assigned based on a 1 to 5 numerical scale 1 indicates the highest rating, strongest performance and risk management practices or strongest compliance position, and least degree of supervisory concern 5 indicates the lowest rating, weakest performance, inadequate risk management practices or substantial noncompliance with consumer statutes and regulations, therefore the highest degree of supervisory concern 7

Types of Examination Safety & Soundness Specialty Examinations, such as Trust and Information Technology Compliance Community Reinvestment Act 8

Safety & Soundness Exams - Focus Focuses on the bank s financial performance and management practices in relation to the CAMELS components: Capital Asset Quality Management Earnings Liquidity Sensitivity to Market Risk 9

Safety & Soundness Exams CAMELS Capital: Absorbs losses, supports growth, and provides depositor confidence Asset Quality: Reflects the quantity of existing and potential credit risk associated with loans, investments and other assets and off-balance sheet items Management: The board and senior management of the bank Earnings: The ability to generate a return on assets sufficient to remain competitive, fund expansion and augment capital Liquidity: The ability to accommodate decreases in deposits and funding increases in assets, both at reasonable costs Sensitivity to Market Risk: Risk resulting from interest rate changes and other factors 10

Safety & Soundness Exam - Frequency Federal law requires that banks receive annual Safety & Soundness examinations Extension of the examination interval to 18 months if a bank: Has a Camels Composite Rating of 1 or 2 and has less than $500 million in assets Is Well Capitalized for Prompt Corrective Action purposes Has management composite rating of 1 or 2 Is not subject to a formal enforcement action Has not experienced a change in control in the preceding 12 months 11

Trust & Information Technology (Specialty) Exams - Frequency Governed by policy, rather than regulation Usually concurrent with Safety & Soundness exams, but may occur separately Conducted at FDIC independent exams and exams with the State (joint exams) where the FDIC is the lead State regulatory agencies may perform specialty exams at their independent exams and during joint exams where the State is lead 12

Embedded Exams Safety and Soundness Reports of Examination will include findings from the Bank Secrecy Act review and can include specialty examination (i.e. Information Technology or Trust) information and ratings If the condition of a specialty area is less than satisfactory, a separate cover Report of Examination may be issued 13

Common Embedded Information Bank Secrecy Act: Targets the bank s compliance with regulations addressing large cash transactions and the bank s anti-money laundering program Information Technology: Assesses the bank s data processing environment, focusing on the components of audit, management, development and acquisition and support and delivery Trust: Focuses on the ability of management to identify, measure, monitor and control the risks of its fiduciary operations 14

Compliance Exams Primary method to determine if the institution is meeting its responsibility to comply with federal consumer protection laws and regulations, including Fair Lending statutes and regulations Blends risk-focused and process-oriented approaches 15

Compliance Exams - Focus Compliance Management System (CMS) which is comprised of the following components: Board and Senior Management Oversight Compliance Program Policies and Procedures Training Monitoring Consumer Compliance Response Compliance Audit 16

Community Reinvestment Act (CRA) Evaluations A CRA evaluation is used by the FDIC to: Assess the bank s record of helping to meet the credit needs of its entire community, consistent with safe and sound banking operations Evaluate an application from the bank for a deposit facility The bank will receive a written, publicly-available Performance Evaluation Uses a separate rating system 17

CRA Evaluations Continued The bank is subject to one of three different evaluation methods based on its asset size for the previous two yearends: Small Institution (<$250 million) Intermediate Small Bank ($250 million $1 billion) Large Bank ( >$1 billion) Other evaluation methods include: Wholesale or Limited-Purpose Strategic Plan 18

CRA Ratings = One composite and two or more individual test ratings for Intermediate Small & Large Banks Small Banks only receive a composite rating Composite Rating Outstanding Satisfactory Needs to Improve Substantial Noncompliance Individual Test Ratings Outstanding High Satisfactory Low Satisfactory Needs to Improve Substantial Noncompliance 19

Compliance/Community Reinvestment Examinations Frequency depends upon asset size and ratings Conducted independently or concurrently with a Safety and Soundness examination 20

Compliance/Community Reinvestment Examinations - Frequency 21

Compliance/CRA Exam Frequency Continued 22

Director Participation During examinations, the FDIC invites directors to: Attend discussions with management Discuss any other issues with the examination staff 23

Examiners May Attend Board Meetings At the examination s conclusion to present findings At least once every three years as required by the FDIC When adverse findings are identified during the examination Upon the request of the board 24

Recap Banks are subject to Safety and Soundness, Compliance and CRA examinations The examination process includes both off-site and on-site analyses Findings and ratings will be presented at the conclusion of the examination Directors are invited to participate 25