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OTS Using New IT Examination Questionnaire
I’m not sure if this is being used across the board for all OTS exams, or just regionally, but the new pre-examination form (officially called PERK, or Preliminary Examination Response Kit) is significantly more comprehensive…
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Dodd-Frank and agency consolidation
Although the specific requirements and burdens of the almost 250 regulations and more than 2000 pages in the Dodd-Frank Act are yet to…
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FDIC can now step in regardless of primary regulator (part 2)
Further to the previous post, the memorandum requires the FDIC opinion to prevail in the event that an institutions’ PFR (primary federal regulator) CAMELS rating differs from the FDIC: If the FDIC’s CAMELS ratings for an institution differ from a PFR’s assigned ratings, the FDIC is required to provide the PFR with an explanation of…
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FDIC can now step in regardless of primary regulator (part 1)
According to a memorandum of understanding just signed by all the primary federal regulators (FDIC, OTS, OCC and Fed), the FDIC now has the authority to step in whenever they feel the DIF (deposit insurance fund) is in jeopardy. Although this is primarily targeted at larger (>$10b) institutions, it also applies to smaller (<$10b) institutions…
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DR/BCP Scrutiny – UPDATED
Auditors (and some FDIC examiners) are scrutinizing disaster recovery plans more closely, specifically looking to verify that the plan structure adheres to FFIEC guidance. We’ve definitely seen this…
