Category: From the Field

The Problem with PEN Tests

This is a true story, the names have been changed to protect the guilty. Al Akazam (not his real name) is an IT consultant with a solid background inRead the rest of the article

April 5, 2013
Examination Downgrades Correlated with Poor Vendor Management

According to Donald Saxinger (senior examination specialist in FDIC’s Technology Supervision Branch) in a telephone briefing given to the ABA in Read the rest of the article

February 25, 2013
Implementing the CFPB-required Compliance Management System (Part 2)

CFPB compliance examinations have only just started and the agency has already identified deficiencies in some institutions: “The CFPB has found one or more situations in which an effective CMS was lacking across the financial institution’s entire consumer financial portfolio, or in which the financial institution failed to adopt and follow comprehensive internal policies and…

February 5, 2013
CFPB Examinations To Require “Compliance Management Systems” (Part 1)

We have known for some time that CFPB examinations are coming, and late last year the CFPB released their Supervision and late last year…Read the rest of the article

January 15, 2013
The Financial Institutions Examination Fairness and Reform Act (and why you should care)

Although it’s currently stuck in committee, financial institutions should be aware of this bill and track it closely in the next congressional session…Read the rest of the article

November 12, 2012
“2 is the new 1″…or is it? (with poll)

UPDATED – October, 2012 – Two institutions in the past ten days have told me that they have been assigned a CAMELS score of “1” in their latest examination. One institution regained their 1 after slipping to a 2 in their last exam cycle, and the other went up to a 1 for the first…

October 18, 2012