Pub. 8 2018-2019 Issue 3

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 November • December 2018 15 C reated by The Coalition of Bankers Associations in 2011, the Regulatory Feedback Initiative (RFI) consists of an anonymous electronic survey for bankers to provide an assessment of their most recent examination or visitation. In 2015 FinPro joined this important effort to assist with analyzing the data generated by RFI. As you know, field examiners complete a survey at the end of every examination that captures their views of your bank’s underwriting standards. While many bankers also have the option to complete a regulatory produced survey at the end of an examination, bankers are reluctant to provide negative comments in a regulatory generated questionnaire. In fact, that is exactly why the RFI was created! RFI was also intended to be a “check and balance” to ques- tionable examination trends and practices. By providing this anonymous feedback, The Coalition of Bankers Associations can have meaningful dialogue with Washington, D.C. agency heads in an effort to correct such acts. Often the RFI data re- veals disparate examination treatment between federal banking agencies, or even sometimes between different offices within one agency. For example, a number of years ago the RFI data revealed that one region within a federal banking agency was taking an inappropriately harsh viewpertaining to Fair Lending examina- tions. The Coalition of Bankers Associations used the RFI data to meet with senior staff in Washington, D.C., and quickly fixed this outlier treatment. Nowwe are starting to see RFI data that indicates question- able examination treatment pertaining to the Liquidity analysis. Quite frankly some of the banker comments are astonishing, but there is not yet a large enough data pool to confirm a problem. While FinPro created the “FinPro Liquidity Matrix” to assist bankers with this troubling trend, the Coalition of Bankers Associations need more banker specific responses in RFI. Re- member, completing the RFI survey only takes 15 minutes and is a critical step to fix examination problems. Forewarned is Forearmed. RFI reports are a great way to learn from your peers what examiner “hot buttons” exist from recent examinations. The more bank data we can capture in the RFI, the more helpful the RFI reports will be in preparation for an upcoming examination. We need to work together. The Coalition of Bankers As- sociations will attempt to fix problems when they exist, but we need the RFI data for support. Renegade examiners can cause significant financial distress. A composite downgrade can cost our banks thousands or millions of dollars. RFI is the “check and balance” to inappropriate or aggressive examination trends. So, what are the next steps? It’s easy, simply copy and paste this link into your web browser and take the survey at http://all- bankers.org/examfeedback.html. There is no doubt that bank- ers are highly sensitive to confidentiality and want assurance that their feedback is protected and anonymous. RFI data is first captured and cleansed byMaritzCX, an independent third party with a track record in collecting anonymous, protected feedback from bank customers and employees. Because the survey is completely anonymous and cannot be linked back to your institution, you will not be able to leave and then return to access your survey; therefore, you will need to be prepared to complete the entire survey at one time. This approach is necessary to maintain confidentiality. Do you have an upcoming examination? Contact the au- thors to request an Exam Preparation Report, a compilation of data collected from surveys taken by bankers from across the county. n Don Musso and Scott Polakoff of FinPro, Inc. Contact them at 908-234-9398 or by emailing finpro@finpro.us Howard Headlee, President of the Coalition of Bankers Associations. Contact him at 801-214- 7722 or by emailing howard@uba.org . Bankers: Your Anonymous Feedback is Critical Please Complete the Regulatory Feedback Initiative