Large Bank Supervision Forum 2023

Best Practices for Large Bank Supervision

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o Compile a list of information that each large bank uploads to their secure file exchange on a monthly and quarterly basis for review o Request monthly board packets, committee packets, and completed audit reports o CSBS legacy excel outliers report is a great tool to use for large bank peer data 4. Quarterly updates/discussions are held with management o Quarterly or biannual updates with all EVPs over the course of a week, depending on the role of the EVP o Topics vary, but an open discussion on what management has been recently working on and expect the next quarter, emerging issues, areas of concern, etc. o Examiners keep meeting notes of each quarterly meeting so everyone on the team can review and add comments o If management typically uses a PowerPoint presentation during ongoing monitoring meetings, ask if the presentation can be sent to examiners 24 hours in advance of the meeting o Send questions to management at least 24 hours in advance of ongoing monitoring meetings o Information from ongoing meetings influence future reviews 5. Conduct annual meetings with key bank board members (including the chairs of the board, audit, and risk committees) 6. Schedule ongoing monitoring meetings that are aligned with bank committee meetings even if they are not during a scheduled exam. For example, schedule an ongoing monitoring meeting after each ALCO meeting and once you have received the materials. It is a good opportunity to ask questions about the materials provided and stay current on emerging developments and management decisions 7. Hold meetings with management for any significant changes before proposed change is approved (ex: increasing CRE limits) 8. Schedule regular meetings with the loan review function and internal audit to keep up to date on emerging risks and their audit scopes and plans. These meeting typically would not involve the first ‐ and second ‐ line managers 9. Continuous monitoring memos are utilized for annual roll ‐ up examination work o Document examiner findings and identify areas for future target reviews 10. Produce notes for board and committee minutes and packages reviewed during the ongoing monitoring review. Those can be good sources of reference materials for later reviews and the next examiner 11. Provide input, obtain, and review the quarterly ongoing monitoring report produced by the Federal counterpart that includes any major changes/events since the last quarter; target review results; and overview of CAMELS, BSA, and IT, as applicable 12. Monitor and track outstanding regulatory issues o Compare and reconcile to the bank’s outstanding issues tracking report

Last update March 1, 2023

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