| Subject: |
Examination Policies |
This bulletin addresses current Bureau policy as it relates
to the examination process. Bank Bulletin No. 15 issued March
23, 1977, is rescinded.
Priority
The Bureau will continue to concentrate its efforts on the
examination, supervision and regulation of problem banks (generally,
those assigned a composite CAMEL rating of 3, 4 or 5). Those
institutions will receive at least one examination by the Bureau
in each calendar year. Additional examinations may be conducted
by the Bureau or Federal regulators as deemed appropriate. Examination
activity will be supplemented with Board/management meetings,
formal agreements, follow-up visits and continuing off-site
surveillance.
The Bureau will ensure that each state-chartered bank is examined
at least once in each calendar year. The Bureau may accept reports
of examinations conducted by Federal regulatory agencies in
fulfilling its annual examination responsibility. Use of the
Federal agency examination will apply only to those banks which
do not present unusual supervisory concern. The Bureau will
conduct its own examination at least once in every 24-month
period.
Scope
In determining examination scope, the Bureau will consider,
among other things, prior CAMEL ratings and examination findings,
uniform bank performance reports, reports of income and condition,
annual stockholder reports, CPA audit findings, adequacy of
audit coverage and internal controls, quality of loan review/administration,
management changes, capital structure, earnings performance
and liquidity. For those institutions considered in a strong
or satisfactory condition, examination scope could be restricted
to development of a CAMEL rating. Examination scope would be
expanded accordingly if a lack of managerial or operational
control becomes evident. The Bureau's Automated Services Division
will continue to conduct examinations of electronic data processing
facilities.
Format
Examination report format is intended to be as flexible as
conditions warrant. Reports may consist of a letter to the Board
of Directors or could consist of a more formal report, complete
with back-up schedules and analyses. At a minimum, examination
reports will be sufficiently comprehensive to disclose component
and composite CAMEL ratings and disclose the rationale for the
rating.
"Off-site" Examinations
The Bureau will continue to be innovative in carrying out
its responsibilities in an efficient, effective manner. The
increased use of off-site examination techniques allows cost
savings to the Bureau while reducing disruption to the bank.
"Off-site" examinations will commence with a formal request
of management for specific information. The examiner-in-charge
will consider that information, along with other externally
generated information, in determining examination scope and
assessing the condition of the bank. "Off-site" examinations
will normally include a visitation to the bank to complete the
examination and conduct an exit interview with management. Examination
findings will be transmitted to the Board of Directors and will
include, at a minimum, identification of scope and a description
of both the component and composite CAMEL ratings. "Off-site"
examinations, when conducted, will only be used in cases where
a bank is considered to be well managed and information indicates
the bank would likely be rated a CAMEL 1 or 2. No bank will
receive two consecutive "off-site" examinations.
Coordinated Examinations
The Bureau is also currently involved in a cooperative effort
with the Federal Reserve Bank, the Federal Deposit Insurance
Corporation and the Comptroller of the Currency, to conduct
simultaneous, coordinated examinations of all affiliated entities
of multi-bank holding companies. The coordinated examinations
not only enable the Bureau to use its examiners and administrative
resources efficiently, but minimize examination burdens on the
bank holding company and its affiliates. The scope for this
type of examination will be developed by all participating regulatory
agencies. Bureau examiners will not participate in the examination
of national banks, nor will Office of the Comptroller of the
Currency examiners participate in state bank examinations.
Please contact the Bank and Trust Division at 517/373-6950
if you have any questions regarding this bulletin.
| Signed: |
Eugene W. Kuthy, Commissioner |
| |
Donald P. Mann, Director, Bank & Trust Division |
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| Dated: |
May 7, 1985 |
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