Pub. 6 2016-2017 Issue 4

14 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 FEATURE ARTICLE LISA GETTER INVCITUS CONSULTING GROUP The OCC reports reported that it had more than 4,000 outstanding MRAs in 2015, but it won’t say what percentage of banks that entails. D on’t be surpr ised if your bank re - ceives a write-up about supervisory concerns after your next exam, wheth- er it’s a Matter Requiring Board At - tention (MRBA) from the FDIC, or a Matter Requir ing At tent ion (MRA) from the OCC. Regulatory Write-ups Point to Emerging Risks in Community Banking The FDIC revealed in the summer issue of Supervisory Insights that 36 percent of banks rated 1 or 2 received an MRBA in 2015. The OCC reports reported that it had more than 4,000 outstanding MRAs in 2015, but it won’t say what percentage of banks that entails. Though the numbers are down – the FDIC says 55 percent of satisfactory-rated banks re- ceived MRBAs in 2011 and the OCC had more than 9,000 outstandingMRAs in 2012 – issues such as commercial real estate concentration risk management may lead to an uptick in the coming years. The FDIC article, “‘Matters Requiring Board Attention’ Underscore Evolving Risks in Banking,” says the write-ups act as an early warning system so potential problems can be fixed before it is too late. The article notes that

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