Large Bank Supervision Forum 2023

Best Practices for Large Bank Supervision

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Vetting Findings

2. A regulatory vetting meeting over findings can help facilitate consistency between the agencies over examination results and presentation of findings to the institution 3. Work with Federal partner to complete vetting memo/document o Discuss completed memo among the examination team to finalize language, tone, and structure of the information o Note any differences of opinion and discuss prior to the vetting  Divergent opinions are not a negative thing, but it is critical that both sides of the discussion be well thought out for the vetting  Sometimes, the difference will be between staff from the same agency and you will act more as mediator, but you will always be expected to choose one side as the best course of action in your opinion  It is especially critical if your opinion diverges from your federal partner. In these cases, you will need to think through your position and support your opinion  If your opinion is based on a state requirement, it may not require much discussion as agency specific requirements tend to be accepted by the other agency 4. Schedule the vetting session with management from both agencies and present the findings o If any issues are not settled during the meeting, agree on a plan to address the outstanding questions/concerns and reschedule additional meetings until all issues are resolved 5. Confirm that you have an agreed upon format for all examination reporting including headers that depict both federal and state regulators o The format used by most states will typically be aligned with the Federal Regulator’s version as they have less flexibility on certain aspects of reporting 6. Ensure any examination or target findings that merit an individual response from Bank management are detailed in several prominent places within the examination report, not just in an individual comment, so they are not overlooked by the Board or not considered to the degree that the finding requires Examination Report

Roll Up Examination

7. A roll up examination is completed annually at the end of the supervisory cycle o The planning and staffing of the roll up is similar to other target examinations and compiles the results of all of the target examinations conducted during the supervisory cycle

Last update March 1, 2023