What Your Examiners Are Thinking About

What’s on your examiner’s mind? Here’s what I heard recently from banking regulators. This should be no surprise

• Top of the list — commercial real estate and liquidity risk management
• Other hot topics include:
  • Asset quality
  • Past dues and nonaccruals
  • Rapid growth
  • Funding sources
  • Overall exam rating, especially chain of events that can lead to improvements or deterioration in capital rating
• Expect to see:
  • More full scope examinations
  • More extensive request lists
  • Examiners on-site longer
  • Risk focused IT and BSA exams

I sat down recently with Cathy Ghiglieri, former Texas Banking Commissioner, who suggested it is particularly important to identify all of your problems before the examiners come to your bank for an examination. This is not always easy since oftentimes what regulators view as problems, bankers do not. But, if the examiners identify problems that you don’t, they will come down harder, will rate your bank more harshly, rate management more harshly, and take a harsher enforcement action.

Understanding what the regulators view as problems and looking at your bank objectively so you can identify the problems before the examiners arrive will allow you to prepare for your next examination for the best possible outcome. Need help? Contact us for more information.