Community Banking Organization Management Group
Overview of FRS Technology Strategies for CBO Supervision
for the
Conference of State Bank Supervisors
Technology Seminar - Atlanta, Georgia
Michael A. Combs
Managing Examiner &
CBOMG Business Technology Manager
October 18, 2011
** Overview of the CBO Examination Process **
Pre-Examination
Examination
Post-Examination
Offsite 1-2 weeks
Onsite 1-2 weeks
Offsite 1-2 weeks
Risk Tiering & Scope Memo
Data Request Letter
Incoming Data from Bankers
Statistical Loan Sampling
Examiner Analysis
Transaction Testing
Management Interviews
Report of Examination
Vetting of Findings
Administrative Updates
Ongoing Supervision
Credit
Review
32%
13%
Financial /
Ops Risk
20%
Exam
6%
Training
13%
Specialty
18%
68%
Mgmt
Evaluation
30%
8-12 examiners go onsite
to the financial institution
Travel
Review
** CBO Supervision Structure **
Community Banking
Organization
Management Group
(CBOMG)
Boston
New York
Philly
Cleveland
Richmond
Atlanta
Chicago
St. Louis
MPLS
KC
Dallas
San Fran
“Technology and Innovation Must Be
Driven By The Business Line”
** Examiners are asking for Technology**
DOT voting exercise at the
2011 Community Bank Examiners Conference
#1 Examiner Priority by a 3-1 Margin was:
Create and Leverage Better Technological Tools
•E-line cards
•E-workpapers
•Report format that auto downloads Call Report Data (e.g. reconsider Genesys)
•Automate ED modules (away from MS Word) so automatically flows to summary of
findings and consolidated summary of findings
•Electronic scanners to scan paper documents from bank in the field
** Analysis of CBO Examination Processes (2010) **
In 2010, the CBOMG sponsored a System-wide analysis of common
business processes to evaluate barriers to efficient and effective
examination work and to seek solutions for implementation nationally.
The following strategy and guiding principles results from that effort:
CBOMG Technology Strategy
Technology Guiding Principles
Deploy high-value, quick-to-market, low-cost,
business-driven tools to examiners that
increase efficiency and improve consistency
and supervisory effectiveness while supporting
risk-focused principles and preserving
examiner judgment.
• CBO examination processes should be more
consistent across Districts.
• Examiner judgment and supervisory
decision-making cannot be automated.
• Technology should free the examiner from
inefficient data collection, routine
calculations and administrative activities.
** CBO Business Technology Map **
** CBO Technology Vision **
E-Workpapers
Data Download from Systems
Surveillance Outliers
Examiner Tool Calculations
Banker-Submitted Data
Embedded Training Materials
Examiner Single Point of Entry
Report
of Exam
Automated Risk-Customized
e-Workpapers
Risk
Tiering
(Quantitative
Factors)
Low
Auto
Create
Examiner
Judgment
(Qualitative
Factors)
Med
Med
Database
Updates
High
High
Data
Reuse
Briefing
Docs
High
MIS and
Adhoc
Queries
** Integration of eWP & Team Space **
Cm
A
•
•
•
•
•
•
•
t
M
t
E
ngs
L
idity
Downloaded Data
ensitivity
Surveillance Outliers
Examiner Tool Calculations
eWP
Customized Analysis
Embedded Training
Single Point of Data Collection
Data Reuse, and Reuse, and Reuse
S
•
•
•
•
•
•
•
Examination Data
Staffing and Calendaring
District-Specific Templates & Forms
District-Specific Tasks & Checklists
Examination “Work-in-Process” Files
Banker Responses to Request Letter
Links to RTS eWP files
Restricted FR
Questions?