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.
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