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The Care and Feeding of Examiners

By Blair Rugh 15 Feb 2017

Despite reports to the contrary, examiners are people too. Their families love them, they bleed when they are cut and their dogs wag their tails when they come home. Examiners are neither your friend nor your enemy. If they find something that you did incorrectly they will bring it to your attention, but so will your boss. And your boss has a lot more control over your future than an examiner does.


You have the ability, to some extent, to determine how painful or painless your next examination will be. If you have an inordinate number of violations, your examination will probably not be a lot of fun, so the real preparation for an examination goes on every day as you supervise compliance in your bank. Outside of that, there are still some do's and don'ts in dealing with examiners. The following are a few suggestions.


First, respond to any request for information that they make before coming on site as thoroughly as possible. Whether the information is good, bad or indifferent, they will ultimately obtain it. The more of the examination work that they can accomplish off-site, the less time they will be with you.


Second, where to house them. I suggest that you do not put them in palatial surroundings with free soft drinks and donuts, so don't put them in the board room. If their surroundings are too comfortable they may decide to stay longer. At the same time, don't put them in a storage closet in the basement next to the furnace. If you have a conference room or training room that is of sufficient size that is fine.


Next, ask them to put all of their questions in writing and respond to those questions in writing as well. That way there is never any confusion about what they asked and what your answer was. Also, in that regard, make sure that your answers are truthful. Someone once told me "Salesmanship is the truth told attractively." In that vein, you can certainly put your best foot forward in your answers, but make sure that your answers are truthful and not deceptive. Also in that regard, NEVER, NEVER, NEVER alter a file to make it appear that something happened that did not, or that something that did not happen, did. If there is something in a file that is damaging, leave it there. One of the most critical components of an examination is that the examiners have confidence in your integrity. If I am your examiner and I believe that you have lied to me about something or that you are hiding something from me, then I am going to make my examination a lot more intensive.


On that same note, if the examiners find a violation and you agree with them, enlist their aid on how you can best correct it and how you can amend your policies and procedures to prevent its occurrence in the future. Get them on your side helping you. It is a unique situation for an institution that can go through a compliance exam with no violations found. If they are found, don't take them personally. On the other hand, if the examiners find something that they believe is a violation but you do not, don't challenge them. If you are one of our compliance customers, contact us and let us review it. If we agree with the examiners we will tell you so. On the other hand, if we agree with you, we will be happy to assist you by communicating with your examiners and help present your case. That way, you are not put in an antagonistic position with the examiners. Also our record of winning is awfully good.


Examinations are a part of banking and unfortunately they are not one of the more pleasant parts. They are somewhat like your semi-annual trip to the dentist. You don't look forward to it, but it is over pretty quickly. If you need a filling that may be painful for a moment but it is also over pretty quickly. Unfortunately however, examiners do not carry Novocain.

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