14 HќќѠіђџȱ юћјђџ юџѐѕȱ2014 FEATURE Checks and balances are important. Without them, power becomes concentrated and abused. The banking industry is perhaps the most heavily regulated business in America. Bank regulators wield enormous power, with few, if any, checks and balances. Regulators hold all the cards, from the smallest operational details to the very survival of a bank. For their part, banks are sworn to secrecy, render- ȱȱ¢ȱ ȱȱęȱ back. In fact most banks have deter- ȱȱęȱ ȱȱ is futile. Regardless, we need to take a united stand for a balanced regulatory system, not only for the sake of banks, but for the communities they serve. To that end, the Coalition of State Bankers Associations has created a tool — the Regulatory Feedback Initiative (RFI) — designed to bring balance and accountability to the system. ȱȱȱȱȱęȱ electronic platform, through which bankers can anonymously relay details about their most recent examinations or visitations. The information is aggregated and analyzed on a national level, in order to identify discrepancies in how bank regulations are being enforced. These discrepancies could exist among different bank agencies, geographic regions or examiners within the same agency. The timing of this initiative is opportune, due to the avalanche of new regulations that will be enforced in coming months. Member banks of the Indiana Bankers Association will be able to request reports from the IBA, summarizing the feedback of similarly situated banks to help prepare for upcoming exams. The goals are to avoid surprises and to identify inconsistencies. This initiative will arm our indus- ¢ȱ ȱȱ¢ȱęȱ amount of hard data, as we advocate for an environment in which banks can succeed. This data help to make our case with regulators, members of Congress and the administration. The information provided by participating banks will help determine whether a member bank is receiving unfair treatment vs. appropriate and consistent regulatory scrutiny. This process will allow banks to shed their isolation without violating ę¢ȱȱ¡ȱ- selves competitively. The survey is powered by Allegiance Inc., an independent third party with a track record of collecting anonymous and protected feedback from bank customers and employees. Since its launch, the RFI has collected exam information from more than 2,000 banks. For the month of April, we are asking every bank that has not already completed a survey for its most recent Safety and Soundness exam and Compliance exam to do so, regardless of when the exams occurred. IBA will be emailing our member CEOs with a link to the survey. This link is the only means of ȱȱęȱȱ¢- mous survey. Following this April campaign, we ask that member banks incorporate the survey into their examination processes following each future examination. The Coalition of Bankers Associations has met with representatives of the Federal Deposit Insurance ǯǰȱ Ĝȱȱȱ ȱȱ the Currency, Federal Reserve and Conference of State Bank Supervisors; to their credit, these agencies appear to welcome the input. They recognize that their processes are not perfect, ȱȱȱ ȱȱĴȱȱ Ĝǯ ȱ ȱȱȱȱȱĴȱ- ency will provide some subtle checks and balances in an otherwise one-sided regulatory process. Even a slight shift in this balance could yield significant returns for local economies and the Indiana banking community, as we emerge from the recent economic crisis and assimilate the new regulatory challenges of the Dodd-Frank Act. Please contact me for more information about the Regulatory Feedback Initiative, or read more at: www.indianabankers.org/regulatoryfeedback-initiative. Time for Regulatory Transparency яќѢѡȱѡѕђȱ Ѣѡѕќџ Rod Lasley is vice president-products & services of the Indiana Bankers Association, and also serves ȱȱȱȱȬęȱȱ ȱ¢ȱ the IBA. He can be reached at 317-387-9380, email: RLasley@indianabankers.org.
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