Independent Banker - August 2018 - 19

date on a regular schedule, practice solid version
control and ensure board of director reviews and
approvals are documented, " she says. " These types
of things are always requested, and, when they are
well-controlled, it allows more time to address
other requests. "
exam requests among different managers, and we
set up a folder on our network as a repository for
all responses, " he continues. " We use a standard
naming convention that aligns to the request list to
make identification of folder contents consistent. "
Boccia urges community banks to log board minutes
with bullet points about " compliance " labeled.
Communication needed
When the first-day letter arrives, there are more
best practices that contribute to better results.
Communication with the bank's team, project oversight
and organization for the exam are essential.
" Treat the exam as project management, " suggests
Boccia. " If you can, dedicate one person with
project management skills to track the activities.
Bring in other key contacts and stakeholders-representatives
from the lines of business, operations,
legal-and conduct exam training, mock exam
scenarios or Q&A sessions to help present a unified,
knowledgeable front to the exam team. "
Brief all bank employees to refer offhand requests
that examiners pose to the point of contact (POC),
and to be mindful of casual conversations about
bank business around the water cooler or in local
places like a café next door.
Loose lips sink ships
Tim Grooms is the chief risk officer for $458 million-asset
First State Bank in Winchester, Ohio.
" Fortunately, we've had few changes in key positions
and little internal reorganization over the course
of several examinations, " he says. " Consistency in
the team helps keep the process efficient. When
there are changes, new players must be integrated
into the bank's exam management process. "
Community bankers should recognize that new
staff members may have either experienced a very
different process at their previous bank or may not
have been in the circle of examination contacts at all.
" We assign one primary POC who is a gateway
for all questions, requests and responses from
start to finish, " says Grooms.
" Before and during the exam, that person may be
able to address an issue personally or may direct
the request to a manager or employee to respond, "
he adds. " The response then flows back through
the POC, who tracks completion and ensures the
response is reviewed for sufficiency. We assign
Check and double check
Before uploading the materials folder for the
examination team, either Grooms or someone
he designates reviews it to be sure it is applicable,
complete and accurate. He believes that this
" We assign one primary
POC who is a gateway for
all questions, requests
and responses from start
to finish. "
-Tim Grooms, First State Bank
significantly reduces examiners' questions and
problems of acceptance.
More help
online
Open the
Compliance
Vault for answers
to almost 2,000
compliance Qs.
icba.org/
compliancevault
When they ask questions, Grooms recommends
paying attention to the specific details and responding
accordingly to answer only the question that
they ask. For instance, if the request is for annual
or monthly information, the response should be
consistent and dovetail with related items without
gaps. Explain any gaps, and, if possible, provide
the missing piece(s) of information to present a
seamless story. Brief memos might be attached
to explain issues, organized and numbered to
correspond to the requests.
To prepare, Grooms says his community bank
uses examination manuals, regulatory guidance,
industry best practices and enforcement actions
to focus on areas that carry higher risk. The previous
examination and internal audit compliance
workpapers and results are also resources.
Bedsole advocates networking to help understand
shifting hot buttons. He says keeping an ear
to the ground about what is happening at other
community banks helps him stay on top of trends.
Once the on-site exam commences, a communication
strategy with the examination team takes
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Independent Banker - August 2018

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