On Course » Sharon » Some tips and tricks for dealing with Regulatory Examinations
Photo Credit: blog.regulatorycompliance.com
- Designate a central point of contact to coordinate examination matters and deliver requested information – the “Examination Manager.”
- The examination manager is the chief liaison with the Examiner in Charge (“EIC”) and the examination team, and will resolve any examination issues while examiners are on-site.
- Designate a management official who can provide an overview of the bank’s operations and can direct operational units under exam review.
- Make sure that the examiners’ requests are promptly met.
- Is the deliverable in the proper format? Don’t keep them waiting!
- Does it convey your message – the right message?
- Have a plan for responding to requests for privileged material.
- Consult outside regulatory counsel.
- Clearly document minutes of exit meetings and forward to Regulatory Counsel
- Know the rules: Be familiar with the examination policies and informal guidelines of the regulators. Research examination handbooks prior to on-site examinations to know what they are going to look at.
- Involve counsel immediately: Comments in exit meeting or supervisory correspondence. Protection of privilege and document control.
- Review comparable enforcement actions: What remedies have the regulators sought in the past? Consider corrective action.
- Do not overreact: Sometimes more regulators/enforcement counsel are brought than are necessary – Shock and Awe!
- Know the players: Learn the relative authority and roles of the supervisory staff. Partner with local examiners to avoid escalation.
- The examiners do not just “go away” – remember their unique role.
Senior Quality Control and Review Specialist
Sharon Geiger has 27 years banking experience, 21 of which have been involved in internal audit. She has extensive knowledge of all aspects of the banking industry, with a particular emphasis on regulatory compliance and identifying risks and controls. As QCR Specialist, she performs Quality Control Reviews to ensure all workpapers and reports are completed in compliance with the firm's standards.