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FDIC can now step in regardless of primary regulator (part 2)

Further to the previous post, the memorandum requires the FDIC opinion to prevail in the event that an institutions’ PFR (primary federal regulator) CAMELS rating differs from the FDIC:

If the FDIC’s CAMELS ratings for an institution differ from a PFR’s assigned ratings, the FDIC is required to provide the PFR with an explanation of the basis for the FDIC’s position. In the event of a disagreement, the matter must be referred to the FDIC Director of the Division of Supervision and Consumer Protection (Director), or other designee, and the appropriate supervision official of the PFR. Any decision by the FDIC to use an assigned rating different than the PFR’s rating must be made by the Director (or other designee), after consultation with the Chairman of the FDIC.

Again, best advice is to adopt the FDIC interpretation of FFIEC regulations, regardless of your PFR.

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Article by Tom Hinkel

As author of the Compliance Guru website, Hinkel shares easy to digest information security tidbits with financial institutions across the country. With almost twenty years’ experience, Hinkel’s areas of expertise spans the entire spectrum of information technology. He is also the VP of Compliance Services at Safe Systems, a community banking tech company, where he ensures that their services incorporate the appropriate financial industry regulations and best practices.

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