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Issue

Examination Review Process Improvement

Each banking regulator has formal appeals processes to dispute exam findings. These processes are time-consuming, expensive, and rarely resolve in a bank’s favor. ABA members are also concerned that appealing will risk examiner retribution.

ABA Position

The agencies need to adopt more informal means of appealing exam findings. One approach would be to vest each agency's ombudsman with the resources that the office needs to be a credible avenue of appeal. That would include having a direct reporting line to the head of the agency, sufficient staff that is seasoned and well-respected within the agency to engage examiners in a productive dialogue, and the right to overrule an exam finding (subject only to being overruled by the agency head).

ABA staff has initiated conversations with each of the banking agencies about creating such a process and will continue to work with ABA members and the agencies to promote the effectiveness and independence of the process for reviewing and/or appealing regulatory examination findings.

Banks and savings associations need a better avenue for appealing examination findings. This issue is particularly important now, given the role of CAMELS ratings in risk-based deposit insurance premium assessments.

ABA staff has initiated conversations with each of the banking agencies about creating such a process and will continue to work with ABA members and the agencies to promote the effectiveness and independence of the process for reviewing and/or appealing regulatory examination findings.

Banks and savings associations need a better avenue for appealing examination findings. This issue is particularly important now, given the role of CAMELS ratings in risk-based deposit insurance premium assessments.

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