Large Bank Supervision Forum 2023

Best Practices for Large Bank Supervision

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o The roll up may also be used to follow up on outstanding findings and any violations or other material issues noted during the year o In some cases, the roll up may be used to target a specific area that was not examined during the year o Lastly, roll up is a time to perform certain annual procedures that did not fit into the prior targets such as verifying call reporting, obtaining Officers Questionnaires and other regulatory reports 8. The vetting and report process is similar to target examinations o Roll ‐ up EICs work with CPCs to bring together all findings and issues o A vetting memo is created and discussed among the roll up examination staff o A vetting meeting is conducted and all conclusions are documented o The annual roll up report is produced and routed through the review process o When completed, the final report is sent to the CFPB by the federal regulator. The CFPB has 30 days to respond with any questions/comments/concerns 9. Following that 30 day period, the CPCs can schedule a meeting with the board of directors of the bank to report the findings o It is recommended that you schedule a meeting with bank management at least two weeks before the board meeting to communicate all findings 10. Roll ‐ up results are presented during a Board meeting o CPCs prepare a PowerPoint presentation for use during the meeting 11. The Roll up process is complete when the final report is mailed to the bank Post Roll Up Examination Process 1. The strength of the regulatory teams (state and federal) relies on routine flow of communications between the two agencies 2. Establish, or follow, the continuous monitoring program for your agency to obtain pertinent information that will help identify emerging/changing risks, new/unusual business segments, and allow examiners to remain fluid with management’s current business plan o This information will help drive the scope of examinations 3. Ongoing monitoring should be utilized to review outstanding findings, monthly board and committee packages and minutes, and other pertinent data o Develop list of specific internal reports, board, and committee minutes that CPCs and specialists would like to review and have the bank produce those items on a quarterly basis VII. Ongoing Monitoring

Last update March 1, 2023