Pub. 11 2016-2017 Issue 3

September/October 2016 27 Extraordinary Service for Extraordinary Members. Regulatory Representation Mergers and Acquisitions Business Succession Planning Litigation eptlawfirm.com toll free 844-704-5296 Omaha Lincoln Newman Grove the guidance “should not be considered as a set of required procedures.” However, others contain language that is more ambiguous. For example, 82-2010 states that “the Guidelines enhance the requirements for collateral valuation methods. . . . ” The mention of requirements is understand- ably confusing. Changes in staffing must be combined with a clearer communication of expectations from the agencies to banks. Continue: The most bipolar results from the current RFI survey data surround exampreparation. Overall, institutions had positive feedback pertaining to the examination staff being “knowledgeable about important issues and regulatory requirements” and “knowledgeable about your institution.” This indicates an adequate level of preparation by staff prior to the examination. However, there have been a significant number of comments pertaining to banks being given short notice to prepare themselves for the examination. Examiners should continue to be vigilant in preparing for the examina- tion and be just as proactive in communicating information about the schedule and timing of the examination as early as possible. In combination with providing examiners feedback, the improved survey and greater bank participation allows for better reports to aid bankers in upcoming examinations. Past comments from the survey included the desires to know such items as: • “that BSA and IT were growing hot topics,” • “there is a new focus on detailed policies,” • “the examiner was going to spend 75 percent of his time on interest rate risk,” • “application of UDAAP specifically to their bank,” • or generally “when the goal posts moved.” We hear you, and the reports from the new survey will greatly improve your bank’s ability to stay aware of hot topics in preparation for examinations. While it is always incumbent on senior managers and directors to stay educated on current industry issues and regulations, the tables above list the areas of greatest criticism in examinations conducted over the last two years.  Bank participation is paramount to the success of the RFI. We encourage all institutions to visit http://www.allbankers.org to share anonymous information about their last examination. If you have questions regarding RFI, contact Jennifer Heaton at the NBA at (402) 474-1555 or jennifer. heaton@nebankers.org . This article is brought to you through the NBA’s partnership with The Coalition of Bankers Associations and FinPro. The Coalition of Bankers Associations represents the unified efforts of bankers associations across the United States to protect and provide critical services to the banking industry. FinPro offers strategic planning, capital planning, regulatory advisory, new director orientation, and board retreat facilitation services. For more information about FinPro, contact Scott Polakoff, executive vice president, or Stephen Brown Klinger, director, at (908) 234-9398 or finpro@finpro.us.  Examination Process — continued from page 11 Exam Area % of Institutions Receiving Criticism Interest rate risk management approaches 24% Credit administration practices 23% Adversely classified asset levels 21% Real estate appraisal and evaluation processes 20% Business Continuity Planning 17% Exam Area % of Institutions Receiving Criticism Real Estate Settlement Procedures Act 24% Regulation Z (Truth in Lending Act) 23% Re HMDA/Regulation C 23% Flood Disaster Protection Act 18% Regulation B (Equal Credit Opportunity Act) 16% Safety and Soundness Examination Compliance Examination