Last month, I attended an ABA Regulatory Compliance teleconference. Towards the end of the conference, an FDIC representative said was that if a Bank has a new product that they are planning on offering to customers, the Bank can call the FDIC and they will personally send someone from the FDIC out to the Bank to review all aspects of the new product prior to the Bank’s implementation.
Having worked on both inside and outside the Bank, I was somewhat perplexed by this offered process. From the Bank’s perspective, usually they do not want to draw any attention to themselves. They want the regulators to stay as far away as possible and only deal with them when they have to. I have in the past had questions that I suggested we called the FDIC about, and the President of the Bank told me, “No Way!”
However, as I pondered for a while, I realized that perhaps the FDIC is actually trying to do something good here. Rather than wait for a potential regulatory violation to be caught during an FDIC examination, perhaps it would be more beneficial for the Bank to have them review the product new prior to implementation, because then any comments the FDIC would have at that time could serve as “advice” up front and save the Bank a regulatory examination finding.
Sounds like a no-lose situation in my opinion.
If you are interested, the FDIC can be contacted at their New York Regional Office as follows:
New York, NY 10118-0110
Toll-free: (800) 334-9593
Local: (917) 320-2500
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