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Regulatory Feedback Initiative works

You may recall that the OBA has invested a lot of time and some capital to help launch the Regulatory Feedback Initiative. The RFI gives bankers a chance to comment anonymously about the bank's examination process, what happened, what problems were raised and how the examiners performed. The idea was to create a database that would show the disconnect between Washington and the real world.

We're reporting to you that the RFI really works, and here's the proof: The Regulatory Feedback Initiative has exposed a major discrepancy in the way Fair Lending is being enforced across the country. Here are the national criticism rates based on more than 1,000 surveys:

FAIR LENDING (HMDA/REG C) CRITICISM RATE:
•  OCC — 20 percent
•  OTS — 28 percent
•  FED — 34 percent
•  FDIC — 60 percent

When we dug deeper into the survey data, we discovered that one (unnamed) FDIC regional office had a Fair Lending criticism rate above 70%! That's not strong, healthy regulation, THAT'S A WARPATH!

We shared this information with FDIC Director Thomas Curry (who has since moved over to serve as Comptroller of the Currency) and guess what happened? Since then, the criticism rate in that region is under 30 percent! Thanks to bankers all across the country this new initiative is really working!

The Regulatory Feedback Initiative, launched by the Alliance of Bankers Associations (which includes the OBA), has created a new level of transparency in the bank examination process. It has revolutionized our ability to hold bank examiners accountable. This will improve the regulatory environment for ALL banks.

But we need every bank in America to complete a "Post Exam Survey" EVERY TIME you finish an exam (both Safety and Soundness AND Compliance.) We urge you to incorporate this into your ongoing regulatory compliance process.

Additionally, your bank has access to the survey data so you can prepare for your exams. You can see exactly how other similarly situated institutions in your region are being treated and what issues are particularly hot.

If you have had an exam in the last year and haven't completed a "Post Exam Survey" please direct your staff to click here and do it as soon as you can. We need to know what happened – the good AND the bad. And then let your staff know this is something they should do after every completed exam.

Thank you! Bankers working together through their state bankers association will improve the regulatory environment for banks in Oklahoma and throughout America.

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