Pub. 3 2013-2014 Issue 6

O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S May• June 2014 11 exam. The federal banking regulatory agencies have reviewed the questions within the survey and have raised no concerns regarding confidentiality; rather, the agencies have expressed strong interest in viewing the aggregated survey results. The Regulatory Feedback Initiative has already achieved suc- cess in helping to improve the quality of banks’ examinations. Based on two years of survey data, the Initiative found that the proportion of survey respondents who were “very satisfied” with their safety and soundness and compliance exams by the OCC rose from 17% in 2012 to 22% in 2013. Even more noteworthy is a victory achieved in early 2012, when significant discrepancies in the way fair lending regula - tions were being enforced nationwide were uncovered due to the Regulatory Feedback Initiative. Based on data received fromover 1,000 surveys completed in 2011, national fair lending criticism rates varied among the four federal regulatory agencies by up to 40%. It was discovered that a regional office of one regulator had a fair lending criticism rate above 70%, while another regulator’s nationwide criticism rate was 20%. After this information was shared with the regulator’s director, the criticism rate in the regional office decreased dramatically, to under 30%. Identifying inconsistencies in how banking regulations are being enforced has never been more important, given the ava- lanche of new requirements resulting from the Dodd-Frank Act. As many of the rules recently became effective, both regulators and the industry are working to understand and implement the new requirements. Bankers have the power to help ensure that the new regulations are consistently enforced across the country. The continued success of the Regulatory Feedback Initiative depends on banks integrating the survey into their ongoing regu- latory compliance processes, by completing a survey immediately following each regulatory examor visitation. One of the primary benefits of the Initiative is the ability to identify discrepancies in “real time”. Bankers have a unique opportunity to improve the industry’s regulatory climate and truly hold examiners account- able, by making their voices heard after each exam. When sufficient data has been gathered from the survey, participating banks may also request a report from their state bankers association that summarizes the feedback of similarly situated banks (based on asset size, primary federal regulator, region, etc.),which can serve as a powerful resource in exam preparation efforts. n More information about the Regulatory Feedback Initiative can be found at: http:// www.allbankers.org/initiative.html. Minimize your risk with CHFA’s Cash Collateral Support program. Banks that use the CCS program will receive cash deposits as collateral for a business loan when the business cannot meet the collateral requirements. Close the deal with more customers. Contact CHFA Community Development today. look out for your small business clients 800.877. chfa (2432) www.chfainfo.com financing the places where people live and work