Introduction to Becoming an MMC EIC Training
Introduction to Becoming an MMC EIC Training
February 7 -9 , 202 3
@ www.csbs.org � @csbsnews
CONFERENCE OF STATE BANK SUPERVISORS 1 300 I Street NW / Suite 700 / Washington, DC 20 005 / (202) 296-2840
Introduction to Becoming an MMC EIC Live Virtual February 7-9, 2023
Tuesday, February 7, 2023 1:00 pm – 2:00 pm
Introduction & Pre-Course Review
MMC EIC - What You Need to Know
2:00 pm – 2:30 pm
Break/Icebreaker
2:30 pm – 2:45 pm
MMC EIC - What You Need to Know
2:45 pm – 4:00 pm
Wednesday, February 8, 2023 1:00 pm – 1:15 pm
Prior Day Review
MMC EIC - What You Need to Know
1:15 pm – 2:15 pm
Break/Icebreaker
2:15 pm – 2:30 pm
Writing the Report of Examination (ROE)
2:30 pm – 4:00 pm
Thursday, February 9, 2023 1:00 pm – 1:15 pm
Prior Day Review
How to Run an Effective Meeting
1:15 pm – 2:15 pm
Break/Icebreaker
2:15 pm – 2:30 pm
Effective Meeting Activities
2:30 pm – 3:30 pm
Wrap Up & Conclusion
3:30 pm – 4:00 pm
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Introduction to Becoming an MMC EIC Day 1
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Introductions
NAME AGENCY AND STATE
YEARS EXPERIENCE AS EXAMINER & EIC
NUMBER OF MMC EXAMS
SOMETHING YOU HOPE TO LEARN DURING THIS CLASS
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Supervising Examiner / Investigator Idaho Department of Finance daniel.kline@finance.idaho.gov Daniel Kline
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Financial Non-Depository Examiner Maryland Office of the Commissioner of Financial Regulation matthew.mainolfi@maryland.gov Matt Mainolfi
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Field Examiner Supervisor Washington State Department of Financial Institutions lindsay.maynard@dfi.wa.gov Lindsay Maynard
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Financial Examiner Field Supervisor Washington State Department of Financial Institutions jacob.monson@dfi.wa.gov Jacob Monson
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Session Learning Objectives: 1. Review pre-course materials
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Session Learning Objectives: 2. Understand the MMC examination process
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Session Learning Objectives: 3. Understand exam management roles and responsibilities of the assigned MMC EIC
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Session Learning Objectives: 4. Discuss SES, including benefits, library, company communications & SES milestones
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Pre-Course Review
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Go to www.kahoot.it and enter PIN
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Key Points – Pre-Course
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Key Points – Pre-Course SES Video
Nationwide system connects agencies & companies
Standardizes supervisory process
Fosters collaboration amongst agencies
Safeguards sensitive information
Readily available risk ‐ based data
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Key Points – Pre-Course
Project Management: Getting Ready Projects are often lengthy & complicated requiring management skills to achieve desired results Project life cycle has various phases
Strategies for project management: • Organize • Implement • Assess & adjust
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Key Points – Pre-Course
Project Management: The Basics
Planning
Controlling
Staffing
Project Manager
Leading
Organizing
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Key Points – Pre-Course
Project Management: Goals & Stakeholders
•Measurable • Realistic
• Expectations • Commitments
•Managed • No surprises!
Project Impact
Objectives
Expectations
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Multistate Mortgage Committee (MMC)
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Multistate Mortgage Committee (MMC) Who is the MMC? • Responsible for coordinating supervision of nonbank multistate mortgage lenders & servicers • Establishing standards • Developing & enhancing training • Scheduling, coordinating & overseeing all MMC exams • Monitoring mortgage industry for risk • Disseminating supervisory matters to state system • Consists of 10 state regulators appointed by CSBS & AARMR Boards
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Multistate Mortgage Committee (MMC)
Anthony Polidori (ID) 2021 MMC Chair
Kristin Rice (NC) Chair
Brenda Fanning (WY) Vice Chair
Allie Wessel (WI)
Anya Tabb (WA) 2022 MMC Chair
Christine Brooks (MD)
Kevin Cuff (MA)
Mark Hastie (MN)
Paul Rhoades (FL)
Sheila Oliver (CA)
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Multistate Mortgage Committee (MMC) What does the MMC do? • Since January 2019, conducted 29 multistate exams, including the OCOE Pilot that closed July 2022 • Works closely with Risk Profiling Group (RPG) to determine the multistate mortgage entities (MMEs) to examine each year • Works closely with Consumer Financial Protection Bureau (CFPB) to conduct 2 ‐ 3 coordinated exams annually • Typically conducts 7 ‐ 10 mortgage origination & servicing multistate exams annually
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Multistate Mortgage Committee (MMC) How is it done? • MMC multistate exam schedule shared with all state agency mortgage contacts each November via an online survey • Survey informs state system of upcoming exams & requests participation, including interest in leading as the EIC or SPOC • Any agency can volunteer to lead an MMC exam • Beginning 2023, MMC limit participation to 10 state agencies per exam • Limiting participants encourages agencies to accept or leverage results & reduces regulatory burden of the MME being examined
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Multistate Mortgage Committee (MMC) Training: • To encourage leadership participation on MMC exams & broaden the pool & expertise of mortgage examiners capable of leading these exams, the MMC introduced this training in November 2021 • Training provides mortgage examiners an understanding of the MMC exam process & the management role & responsibilities of the EIC
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Multistate Mortgage Committee (MMC) MMC Efforts: • Continuously works to improve multistate supervisory & exam process • Recent projects include revising MMC Mortgage Examination Manual, streamlining MMC Report of Examination, drafting next iteration of OCOE Protocol & developing uniform mortgage exam programs & standards for all single state & multistate exams conducted through SES • Goal is to transform a 50 ‐ state supervisory system into a nationwide, networked system using common policies, practice & standards to prioritize exams based on risk & resource availability
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How to Coordinate an MMC Examination
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What you need to know: • Participants
• Communication • Overview of SES • Examination Process • Timing / Schedule
• Resources • Technology
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Participants
Teamwork makes the dream work.
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Participants
MMC EIC
COMPANY
SPOC
STATES
MMC
CSBS
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Participants
• Project Manager • Facilitator • Should not lead a
complex subcommittee
MMC EIC (you!)
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Participants
• Make exam run as smoothly & efficient as possible for: • State examiners • Company • Ensure: • Path is clear • Expectations are known
MMC EIC (you!)
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Participants
EIC Definition in SES: • Agency user role • Responsible for: • Scoping examinations
• Assigning examination tasks • Generating & finalizing ROE • May conduct examination tasks & document findings
MMC EIC (you!)
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Participants
Individual EIC Knowledge and Experience Utilize it!
MMC EIC (you!)
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Participants
MMC EIC
SPOC
COMPANY
MMC Liaison
STATES
CSBS
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Participants
Single Point of Contact (SPOC) for MMC EIC
SPOC
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Participants
• Mentor/Advisor • Liaison • Resource
• Participates in meetings • Reviews draft documents
SPOC
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Participants
MMC EIC
COMPANY
SPOC
MMC Liaison
STATES
CSBS
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Participants
MMC Liaison • Assigned to exam • Technical & examination support • Escalation of issues to MMC
MMC Liaison
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Participants
MMC EIC
COMPANY
SPOC
MMC Liaison
STATES
CSBS
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Participants
• CSBS Support Staff • Administrative & logistical support • Questions about: • Exam process • Technology • Assist with updates to MMC
CSBS
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Participants
MMC EIC
COMPANY
SPOC
MMC Liaison
STATES
CSBS
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Participants
State EIC • Primary contact • ROE:
• Write their State section • State-specific findings • Update State Management
STATES
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Participants
State Examiners • File reviewers • Subcommittee leads • Write section
STATES
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Participants
State Management • Reviews State section ROE • Require elements included/excluded
STATES
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Participants
MMC EIC
COMPANY
SPOC
MMC Liaison
STATES
CSBS
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Participants
Company Primary Contact: • Questions & requests • Scheduling • Coordinates meetings • Company Lead in SES • All exam-related communications & information
COMPANY
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Participants
Company Management: • Meetings during exam • Coordinated through
Company Primary Contact
COMPANY
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Poll Question: Which of the following is not a participant on an MMC exam? • MMC EIC
• SPOC • CSBS • Company • AARMR
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Communication
Conference Calls, Emails, Notes, Oh My!
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Communication
States
Company
MMC
Conference Call Tips
Meeting Notes Tips
CFPB
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Communication - States
Meetings
Conference Calls
Emails
SES
EIC
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Communication - States
State Examination System (SES) • Interactions here
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Communication - States
Email • Reminders • File structure path
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Communication - States
Conference Calls • Specific questions during roll call • Schedule around exam events • Take notes & post
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Communication - States
Conference Call Schedule Example
Mid ‐ Week Check ‐ Ins (on ‐ site)
Weekly (pre ‐ exam)
Week After On ‐ Site
Introductory
Week Report Submissions Due
Company Response
Finalize Ratings
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Communication - States
Introductory Call: • Introductions • Ice breaker
• Loan file submission • Preliminary findings • Examiner participation
• Expectations of roles • Schedule / exam plan • SES & Box
• Summarize examiner profiles • Subcommittee assignments
Introductory
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Communication - States
Weekly: • New Findings • Due dates • MMC resources available • Soft Exit & subcommittee assignment meetings
Weekly (pre ‐ exam)
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Communication - States
Mid-Week Check-Ins: • New Findings • Due dates • MMC template • Plan for soft Exit
Mid ‐ Week Check ‐ Ins (on ‐ site)
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Communication - States
Week After On-Site: • Thank examiners • New findings • Final request & write-up deadlines • Template reminder • Due dates
Week After On ‐ Site
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Communication - States
Week Report Submissions Due: • Any issues
• Template reminder • Write-up deadline
Week Report Submissions Due
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Communication - States
Finalize Ratings: • Thank examiners • Finalize ratings
• Issues or concerns with Report • Draft report review & approval
Finalize Ratings
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Communication - States
Company Response: • Discuss issues • Discuss insufficient responses & need to obtain additional response, or MRA in SES
Company Response
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Communication - Company
Meetings
Phone Calls
Emails
SES
EIC
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Communication - Company
Call Schedule Example
After Loans Received & IRs Start
After Loan Request Sent
Week Before On ‐ Site
Introductory
Other Possible Calls
Week After On ‐ Site
Exit
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Communication - Company
Introductory Call: • Introductions
• Number of states • Schedule overview • On-Site week • Loan list provided • On-Site needs • Company questions • Thank company
Introductory
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Communication - Company
After Loan Request Sent: • Issues with due dates • Schedule overview • On-Site week • Loan level request timing
After Loan Request Sent
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Communication - Company
After Loans Received & IRs Start: • How requests will work & are working • Finalize on-site week schedule & expectations
After Loans Received & IRs Start
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Communication - Company
Week Before On-Site: • Finalize schedule & expectations • Answer any Company questions • Handle any scheduling hiccups
Week Before On ‐ Site
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Communication - Company
Week After On-Site: • Thank Company • Discuss timelines • Overview of schedule • Answer Company questions
Week After On ‐ Site
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Communication - Company
Other Possible Calls: • Soft exit • Enforcement actions • Delays
Other Possible Calls
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Communication - Company
Exit Meeting: • Final exit with Company • Time zones
Exit
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Communication – MMC, SPOC & CSBS
Phone Calls
Emails
SES
EIC
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Communication
Tips for Conference Calls: • State your name • Roll call & introductions • Ask questions of each state individually • Remember to pause…. • Outline before call • Ask if you missed anyone or if anything else to add
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Communication
Tips for Meeting Notes: • Taken for each meeting • State Conference Calls • Note Taker for subcommittee meetings • Save notes on SES Interactions page
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Communication - CFPB
Coordinated Exam Communication Schedule
Develop Communication Plan
Initial Company Meeting/Call
Scoping and Planning
Weekly Meetings (pre ‐ exam)
Post Exam
Exam Week
Close ‐ Out
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Overview of SES
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Overview of SES
SES Benefits
Library
Company Enrollment/Communications
SES Milestones
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Benefits of SES
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Benefits of SES - Regulators
Standardize Collaborate
Data
Safeguard
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Benefits of SES - Regulators
Standardize • Supervisory process
Collaborate
Data • Risk ‐ based • Readily available
Safeguard
• Foster
• Sensitive
amongst state agencies
information
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Benefits of SES - Companies Consistency Reduced Burden
Assurance
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Benefits of SES - Companies
Consistency • Single system
Reduce Burden
Assurance • Ability to track
• Reduces
interaction with regulators
number of individual information requests
communications with regulators
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Overview of SES
SES Benefits
Library
Company Enrollment/Communications
SES Milestones
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SES Library
Areas for Review
Information Requests
SES
References Procedures
84
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SES Library
Areas for Review
Information Requests
SES
References Procedures
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SES Library
Information Requests
Areas for Review
SES
References Procedures
86
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SES Library
Areas for Review
Information Requests
SES
Procedures
References
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SES Library
Areas for Review
Information Requests
References Procedures SES
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SES Library Management
• Agency Specific Items • Standard Library Items • Core • Non-Core
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SES Library Management
Standard Agency Specific
1 2
90
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SES Library Management
Non Core
Core
1 2
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SES Library • Investigations: • C ore & non-core are not automatically added • State to Standard Match Report • Staff User & Staff Director manage the Library
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SES Exam Scope
• Initiating a Supervisory Activity • Managing the Scope • Core AFRs for Mortgage:
• Origination Exams • Servicing Exams
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Overview of SES
SES Benefits
Library
Company Enrollment/Communications
SES Milestones
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Company Enrollment
Agency Sends SES Enrollment Request to Company
Company Receives Email to Activate Okta Account
Company Logs into SES
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Company Communications
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Overview of SES
SES Benefits
Library
Company Enrollment/Communications
SES Milestones
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Overview of SES
SES Milestones
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SES Milestones
Pending
Scheduled
Planning
In ‐ Flight
Drafting
Close ‐ Out
Closed
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SES Milestones
If EIC holds Staff Director or Staff User role: • Initiate SA • Send SA for Review • Add SA Participants
Pending
100
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SES Milestones
• Define the Scope • Send Scope for Review (optional) • Add and/or update SA Participants
Scheduled
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SES Milestones
• Define the Plan • Send Plan for Review (optional) • Send Loan Requests & IRs to Company
Planning
102
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SES Milestones
• Review Findings • Schedule Exit Meeting • Upload Report
In ‐ Flight
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SES Milestones
• Assign Package Assembler • Add MRAs • Review/Send MRAs to Company
Drafting
104
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SES Milestones
• Review & Respond to MRAs • Close MRAs • Enter Close-Out Information • Mark Report Response Complete
Close ‐ Out
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SES Milestones
If EIC holds Staff Director or Staff User role: • Close & Lock the SA
Closed
106
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Examination Process
“The secret to getting ahead is getting started.”
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Examination Process
• Where do you start? • Where are you going? • How do you get there?
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Questions
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Examination Process
Beginning • Requests On-Site Week
Report Writing
Ratings
MMC Review of Draft ROE
Final Exit & Final Report
Response Review
Closing the Exam
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Examination Process
Beginning: • MMC chooses Company • You are chosen as the EIC • You receive email notification (typically, 120 days before onsite start date) • Determine subcommittees with SPOC • Determine subcommittee leads • Ask States for initial information requests • Initial calls – Company, States • Send initial information requests to Company
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Examination Process
Requests: • Types: initial, loan, subcommittee, additional • State requests • Company responses • Ensure request process, file naming & structure is clear to both the States and the Company
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Examination Process
On-Site Week: • Introductory meeting/tour
• Subcommittee meetings (calls) • State check-in call mid-week • Soft Exit
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Examination Process
On-Site Week - Preparation: • Inform Company: number of examiners, equipment needed, weekly/daily arrival & department times • Subcommittee meeting schedule • Assign note takers to each meeting • Ask States to prepare meeting outline prior to on-site week
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Examination Process
Report Writing: • MMC Template • Provide States MMC Finding Template
• Compile state sections into Report – One Voice • ROE revisions – do not reformat template unless approved by MMC Liaison
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Examination Process
Ratings: • Use MMC Template ratings • Ask each State to record their preferred ratings(s) during their review of the Report • Discuss ratings as a group during State call • MMC determines final ratings
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Examination Process
MMC Review of Draft ROE: • Timing • Authority • MMC determines final ratings
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Examination Process
Final Exit & Final Report: • After approved by MMC, provide Final ROE & ROE Cover Letter to Company • Host Final Exit call with Company & States • Determine State assignments prior to call • Be prepared for questions • Most important attendees: Company main contact(s), MMC EIC & the SPOC
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Examination Process
Response Review: • Notify participating States • Request States review state-specific finding & subcommittee responses • Schedule call to discuss review process, next steps & deadline • Centralize questions with EIC for follow-up with Company • Once review is complete, EIC draft closing letter
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Examination Process
Closing the Exam: • MMC Template closing letter • Notify CSBS Staff • Send thank you email to States & MMC Staff
120
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Timing/Schedule
“A goal without a plan is just a wish.”
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Timing/Schedule
Outline of Exam
Planning On-Site Week
Scheduling Meetings
EIC’s Time
122
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Timing/Schedule
Outline of Exam • Use MMC EIC – SPOC Timeline to determine due dates • Use your own running excel calendar for exam team • Due dates need to be shared early and repeated often • Share EIC’s schedule (work schedule, leave, etc.)
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Timing/Schedule
Planning On-Site Week • Understand State work hour expectations & time zones • Create schedule for week • Ensure Company representatives meet the needs of the subcommittee lead examiners • Plan 30-minute meetings with 30 minutes between each meeting • Allow for two rooms • Assign note taker to each meeting • Ensure expectations of meetings are clear & communicated to both States & Company
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Timing/Schedule
Scheduling Meetings • Understand time zones & work schedules • Consistency for recurring meetings • If you don’t need an hour, don’t schedule an hour • Determine key participants
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Timing/Schedule
EIC’s Time • Key to successful examination is MMC EIC is given TIME to be the EIC
• Communication and answering questions • Organization and scheduling meetings
126
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Timing/Schedule MMC Exam Timeline – Prior to Exam Start
Request ISB/EP Form
EIC & SPOC Call Company
90
80
120
60
Exam Notification Letter
Exam Plan & IR Due Date
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Timing/Schedule MMC Exam Timeline – Prior to Exam Start
Loan Selection EIC & SPOC Call States
Loan File Delivery
45
30
15
7
On-Site Schedule & Exam Plan
EIC & SPOC Call States & Company
128
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Timing/Schedule MMC Exam Timeline – Post Exam On-Site
MMC ROE Preparation
EIC Notify SPOC
1
21
30
States Submit Findings & Assignments
129
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Timing/Schedule MMC Exam Timeline – Post Exam On-Site
EIC Notify States Draft ROE
EIC/SPOC Notify MMC
45
60
70
EIC Notify SPOC Initial Draft ROE Ready for Review
130
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Timing/Schedule MMC Exam Timeline – Post Exam On-Site
Draft ROE to SPOC & CFPB
EIC Sends Final ROE to Company
80
90
75
SPOC Notifies MMC ROE Ready for Review
131
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Resources
“All the resources we need are in the mind.”
132
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Resources
Manual
Templates
Subcommittee Guidance
Contacts
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Resources
Manual
Rating Information
Regulation Information
134
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Resources
Templates
• MMC Uniform Exam Findings Template • MMC Origination ROE Template • Letters • MMC Examination Plan
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Resources Subcommittee Guidance
• MMC Compliance Management System Exam Procedures • Financial Condition Exam Procedures • MMC BSA – AML Program Examination Procedures • MMC Mortgage Examination Manual • Past Exams – request & make available at beginning of Exam • Ensure you have most current versions!
136
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Resources
Contacts
SPOC • Exam procedures, timelines, expectations • Report writing/template • State accountability • Company conflicts
CSBS Staff • Exam procedures, timelines, expectations • Technology questions
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Technology
“A computer will do what you tell it to do, but that may be much different from what you had in mind.”
138
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Technology
Helpful Contacts & Resources
Encrypted Email
Technology Overview
File Organization
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Technology
Technology Overview
External Software
SES
Box
140
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Technology
• Plan file organization before files are received
• Organize files clearly, simply & consistently
File Organization
• Include file pathway when referencing documents in email or in call notes
• Always offer to help find documents
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Technology
Resource Portal SES Call Center RUG CSBS Support Staff
Helpful Contacts & Resources
142
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Technology
• All email communication
Encrypted Email
• Ensure States are aware of this at the beginning of the exam
• States may have different programs
143
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Questions
144
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145
Internal Use Only
Resources List of SES Agency Knowledge Articles: • List of SES Articles
Knowledge Articles - Library: • Understanding the Library • Managing the Library
146
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Resources Knowledge Articles - Scheduling: • Taking Action on Your Exam Scheduling To-Do List • Using Exam Scheduling
Knowledge Articles – Company Enrollment: • SES Company Enrollment Process • Initiating Company User Enrollment
147
Internal Use Only
148
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SES EIC R OUNDTABLE – S UGGESTED B EST P RACTICES FOR M ULTI -S TATE E XAMS IN SES
The Exam Plan – Communicating Across the Team • If more than one examiner is assigned to an Area for Review (AFR), the AFR owners should communicate the procedure assignments to the EIC outside of SES. The EIC then enters the details in the exam plan of SES. • For easier communication with the exam team about procedure assignments outside of SES, use the ‘Export to Excel’ feature from the Procedures Quick View filter on the Examination tab. • When more than one state is assigned to an AFR, the EIC should share contact information with the AFR owners so they can contact their additional contributors. • Be mindful of general component ratings (specific to MMC exams) and exam review areas when assigning AFRs. Example: On your multi-state exam, it may be best to assign a single examiner to all financial AFRs, so they are able to get an overall picture of the company’s financial condition. Using Matters Requiring Attention (MRAs) • Exam team should include the SES Finding # and/or assigned Areas for Review (AFRs). • If an MRA is directly related to a Finding, the MRA should be associated to the Finding. • MRAs should only be added if response is required from the company once the Report of Examination (ROE) is issued. • MRAs may be leveraged for Report content; content should be written appropriately for inclusion in the Report, if warranted. • Exam participants should contact the EIC outside of SES if changes are made to MRAs, so the EIC can re-review prior to sending.
Documenting Findings • Consistency is key. • Findings can be entered as a Violation, Recommendation, or Observation; discuss how each will be used with the exam team. • Exam team should associate any applicable loan files to their Findings created in SES. • Finding Commentary will be leveraged for Report content; content must contain sufficient detail to support the Finding and be written appropriately to warrant inclusion within the Report. • Exam team should notify the EIC if they edit their Findings; SES does not alert the EIC if a change is made but the EIC can use the “last modified on” field to identify edits. • Only the EIC can delete Findings in SES. Preparing for a Multi-state Exam in SES • Set expectations for team’s use of the system. • Schedule consistent bi-weekly team meetings. • Agree how the team will communicate. • Review Information Requests (IRs) before the exam. • Identify any state specific requests to avoid duplicative IRs. • Share the spreadsheet of IRs with the exam team early to assist with defining the scope. MRA = Matters Requiring Attention System functionality used by the agency to correspond with the company after the report is sent and/or after the closure of the examination or investigation.
Conducting the Exam Work • EICs should notify the exam team when Information Requests (IRs) and Loan Requests are fulfilled. • Since anyone with the examiner role can send follow-up requests for IRs on a multi state exam, EICs should set clear expectations regarding who should be sending follow-up requests to initial IRs. • If there are 10+ agencies conducting loan file reviews, set delivery dates for the company by agency (highest volume to lowest). • Provide clear instructions on where the Areas for Review (AFR) Commentary should be added for AFR owners; in SES the AFR Commentary should be added to AFR Summary documentation vs. Report Commentary. • You can remove a loan file from the Complete status so that you can send it back to the company. Click update loan file and save in progress to revert the status. Using the Peer Review Report Workflow • This method is helpful for conducting simultaneous reviews of the draft ROE. • Peer Reviewers must be added as a participant on the exam to review the ROE. • Set clear expectations with Peer Reviewers on how they will use SES to comment on the ROE.
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Introduction to Becoming an MMC EIC Writing the ROE
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Session Learning Objectives: 1. Apply critical thinking to develop better report content
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Session Learning Objectives: 2. Discuss best practices for report writing
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Session Learning Objectives: 3. Apply concepts to writing exercises.
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Writing the Report of Examination (ROE)
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What do you think is most important when writing the ROE?
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Writing the ROE The ROE should provide a clear, concise, and objective evaluation of the examinee’s overall condition.
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Writing the ROE The ROE is the principal vehicle used to communicate examination findings and need for corrective actions.
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Writing the ROE
Communication is essential to the proper development of examination findings and overall conclusions.
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Writing the ROE
Critical Thinking Relevant and accurate findings
Appropriate Content Information that is easily understandable
Appropriate Structure Information that is easily followed
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Structure
Structure should be logically, simply, and consistently arranged.
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Structure Examination Purpose
Examination Scope Overall Summary/Component Sections Examination Findings – Expectations/Recommendations - Conclusions Violations of Law & Consumer Harm State/Federal Examination Finding - Recommendations Conclusion
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Content
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Content
• Be accurate • Reflect the appropriate tone • Provide explanation and support for findings
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Content
Do Not: • Make unsubstantiated assertions • Overwhelm the reader • Include unnecessary technical terms or jargon
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Content
Plan: • Before you write • Focus on points to include rather than
struggling with words
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Content When first introducing an agency, acronym, or abbreviation, write out the full name followed by the abbreviation in parentheses. For Example: • The Consumer Financial Protection Bureau (CFPB) • Report of Examination (ROE) • North Carolina Commissioner of Banks (NCCOB)
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Content Write your initial draft Wait a day or two before reading it over – fresh perspective Use spell check, then read your work If in doubt, look it up! Take pride in your writing; turn in your best possible work.
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Content
Ask yourself: • Is the language within the ROE simple, nontechnical, and clear? • Can management understand the terms, concepts, and relationships? • Do paragraphs contain topic sentences that summarize the main idea? • Does each section have a lead paragraph which provides a summary and analysis? • Do the paragraphs that follow provide support, substantiate, and explain the analysis?
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Content
Ask yourself: • Do all sentences within each paragraph have both unity and coherence? • Are sentences sufficiently short and clear to allow readers to understand them? • Is the tone of the ROE appropriate in respect to the ratings assigned? • Does the report focus on the important issues identified by the examination team?
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Content
Ask yourself: • Is the level of detail sufficient to convince readers of the problem, but not so minute to hinder the message? • Has each section of the ROE been filled out? • Is each area identified in the scope addressed in the body of the ROE? • Will recommendations resolve issues?
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Content
Ask yourself: • Does the ROE establish the significance of the conditions? • Does the report provide a proper perspective of the strengths and weaknesses of the company? • Does the summary section provide the results of the examination findings and their significance without specific detail? • Do findings clearly identify the applicable state or federal law, rule, or regulation?
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Content
Ask yourself: • Are findings adequately developed? • Did you double-check facts, figures, and proper names?
• If information remains to be inserted at the last minute, highlight the omission prominently so that no one forgets.
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Resources • The Business Writer’s Handbook: http://www.grammarbook.com
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Exercise
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Critical Thinking
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Critical Thinking Includes:
Thinking systemically • Review all exam information wholistically • Identify findings & deficiencies • Reach an informed conclusion based on evidence & write it up
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Critical Thinking Includes:
Asking questions • Why am I being told this? • Who is telling me this? Do they have vested interests and/or bias? • What am I not being told? • Where is the evidence to support this?
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Critical Thinking Includes:
Asking questions • How much of this is rhetoric? • How else might you read the same data? • What are the implications of this? • How reliable is this information?
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Critical Thinking Includes:
Stepping back from personal feelings
Examining data from different angles
Checking the accuracy of information
Checking the logic of the argument
Looking for possible flaws in the argument
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Critical Thinking Includes:
Looking beneath the surface & challenging your thinking
Understanding why other people see it differently
Checking assumptions
Understanding link(s) between issues
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Content - Style & Grammar
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Content - Style & Grammar
Write out full names followed by the abbreviation in parentheses. Examples: • The Consumer Financial Protection Bureau (CFPB) • Report of Examination (ROE)
Acronyms
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Content - Style & Grammar
Do not use an apostrophe for a plural acronym.
Acronyms
Incorrect Example: ATM’s, CD’s
Correct Example: ATMs, CDs
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Content - Style & Grammar
Active Voice: The subject of a sentence performs the action. Emphasis is placed on the person or thing taking the action. Passive Voice: The subject of a sentence receives the action. Emphasis is placed on the person or thing acted on.
Active Voice vs. Passive Voice
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Content - Style & Grammar Active Voice Passive Voice
The company sent the file on Monday.
The file was sent by the company on Monday. Confidential information was deleted by the processor. It is believed by the borrower that the fee must be paid by the lender.
The processor deleted confidential information. The borrower believes the lender pays the fee.
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Content - Style & Grammar Active Voice Passive Voice
Joe took the application.
The application was taken by Joe.
The agency fined ten companies for misleading advertising.
Misleading advertising was the reason the agency fined ten companies. New employees were hired by the licensee last month.
The licensee hired new employees last month.
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Content - Style & Grammar
There are numerous exceptions and options to basic capitalization rules. The most important rule is to be consistent.
Capitalization
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Content - Style & Grammar
Common Examples: • Capitalize “Report of Examination” and “Report” when referring to a specific report. • Do Not Capitalize “examiner-in charge” unless it is followed by a specific person’s name.
Capitalization
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Content - Style & Grammar
Common Examples: • Capitalize the titles of formal institution policies. • Capitalize the titles of specific institution committees.
Capitalization
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Content - Style & Grammar
Common Examples: • Titles of rank, honor, or respect are Capitalized when they precede the name. • Do Not Capitalize titles when they follow the name. • Capitalize “State” or “Federal” when referring to a public agency, otherwise, do not.
Capitalization
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Content - Style & Grammar
Use a comma between the city and the state, and after the state. Write out the name of the state in the report. Example: The bank is in Charlotte, North Carolina, and has a branch in Fairfax, Virginia.
Cities & States
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Content - Style & Grammar
Write out dates.
Dates
Example: February 7, 2007
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Content - Style & Grammar
Use a comma between the day and the year, and after the year. Examples: • December 25, 2020, is Christmas Day. • The March 31, 2020, Call Report is due.
Dates
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Content - Style & Grammar
Do not use a comma if using only the month and year. Example: • Our meeting will be in January 2004.
Dates
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Redundancy: • The company is small in size. • The company’s past history is successful. • The file contains wrong and inaccurate information.
Elements to Avoid
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Content - Style & Grammar
Unnecessary/filler words: • Regardless of the fact that versus although • During the course of versus during • Some experts commonly believed that versus some experts believe
Elements to Avoid
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Intensifiers: • I strongly disagree with the owner. • The loan is very bad. • The sample is very small.
Elements to Avoid
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Content - Style & Grammar
Adjectives
Hyphenation
General Rule: • Hyphenate connected words that function as adjectives if they occur before the word they modify. • Do Not Hyphenate connected words that function as adjectives if they occur after the word they modify.
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Content - Style & Grammar
Examples • A full-scope, on-site examination began on June 30. • June 30 is the date the examiners arrived on site. • A 50-unit complex was for sale. • The apartment complex has 50 units.
Hyphenation
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Content - Style & Grammar
Prefixes and Suffixes
Hyphenation
General Rule: • Words containing prefixes generally do not require hyphens . • However, a hyphen is used with a prefix when the root word is a proper noun. • A hyphen may be used when the prefix and root word begin with the same vowel.
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Examples • nonaccrual, nonperforming, subtotal, noninterest • anti-American, anti-inflammatory
Hyphenation
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Content - Style & Grammar
Compound Words
Hyphenation
General Rule: • Compound words may be written as one word, two words, or with a hyphen . • If you are not certain if a compound word should use a hyphen, check a dictionary .
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Content - Style & Grammar
• A compound NOUN is a noun made with two or more words. • If you do not find a compound noun in a dictionary, write the components as separate words. Examples: • on the blackboard • inspect the swimming pool • financial well-being
Hyphenation
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Content - Style & Grammar • A compound VERB is a verb made up of multiple words.
• If you do not find a compound verb in a dictionary, hyphenate the components. Examples:
Hyphenation
• water-proofed the roof • will reconvene tomorrow • shortchanged the teller
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Content - Style & Grammar
• If modifier is an ADVERB ending in –ly, do not use a hyphen. Example: • privately held company
Hyphenation
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Content - Style & Grammar
List comparable items & use parallel structure.
Lists & Bullets
Do not end an item on a list with a period unless it is a complete sentence.
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Content - Style & Grammar
Use bullets, as opposed to numbers, when rank or sequence is not important.
Lists & Bullets
If a bullet contains multiple sentences, consider another format.
Long bullets should be avoided.
DO NOT use for just one item.
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Content - Style & Grammar
Spell out numbers one through ten.
Numbers
Use figures for numbers 11 and over.
Spell out numbers at the beginning of sentences.
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