Show them you get it.
We can help you craft a response that shows
(1) you understand the problem and
(2) intend to fix it.
Sometimes, due to misunderstandings or lack of clear communication, a bank may get seriously negative examination criticism. Typically, these citations require the institution to evaluate the examiner’s position and respond in writing with a detailed “plan of remediation”. We can help the bank prepare a clear, concise response. If there is a “counter-case” to be made, we can help position your defenses. Bankers should keep in mind that an exam response lives a long time. It needs to be written by a good communicator. It must be convincing. And, it must set forth “do-able” remediation fixes and a reasonable time to achieve compliance.
We hope you never have to deal with this issue. But, if it happens, call us. It doesn’t cost anything to talk it over.
Here’s how to get the ball rolling:
- Call to discuss your needs and to obtain our Certificate of Non-Disclosure and Privacy Agreement.
- If we’re only spit-balling, than skip Step 3. We don’t charge for conferences or to share our experience.
- Review our Fee Proposal. If it is acceptable, go to next step. NOTE: depending upon the circumstances, not all information request may be necessary. The rule of thumb: if you’re paying us, we want as much information as possible. If we’re just talking, then less information may be forthcoming.
- Provide some information for our discussion session. Some, all or none of the below maybe appropriate.
- Summarize examination comments (positive and negative) along with examiner recommendations and send those to us. Include in your summary both the written comments as well as any oral communication that took place. NOTE: we may not need to see copies of the actual comments; we can always review with a GoToMeeting session.
- Gather up your current policy and procedures along with any documents you use to open accounts or perform the work. You can scan and email to our secure portal or fax them to us.
- Gather your current reports you are using now to manage compliance.
- Summarize your current monitoring efforts; provide copies of reports used.
- We’ll send you a checklist you can use to help us understand the specifics of how you operate this part of the bank and how you are managing the compliance piece.
- We’ll send you the “prelim” policy and procedure in a MS WORD format to review and revise.
- We’ll schedule a follow-up phone conference to review your changes.
- We’ll send the revised Policy and Procedure.
- You provide credit card for our billing. (Payment by ACH and/or check is also acceptable.)
They came in to help us a few years back. We liked the way they do business. They’re focused on helping us, not on their billing. One of their execs serves on our compliance committee and is a big part of our compliance management.Community Bank CEO