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Financial Services Law Insights and Observations

Fed tailors state member bank exams to risk

Agency Rule-Making & Guidance Federal Reserve Supervision Examination Risk Management

Agency Rule-Making & Guidance

On June 3, the Federal Reserve Board issued supervisory letter SR 19-9 to provide guidance on its enhanced process for determining the scope of safety-and-soundness examinations of community and regional state member banks (SMB). Under the “Bank Exams Tailored to Risk” (BETR) process, the Fed intends to “gauge the risk of a bank’s various activities [and] facilitate[] a more data-driven approach to the risk tailoring of supervisory work.” A SMB’s level of risk within individual risk dimensions—such as credit, liquidity, and operational risk—will be derived from a combination of surveillance metrics and examiner judgment.

Among other things, BETR’s objectives are to (i) apply appropriately streamlined examination work programs to identified low-risk activities, in order to conserve supervisory staff resources and minimize regulatory burden; (ii) direct enhanced supervisory resources and attention to identified high-risk activities; and (iii) implement average intensity examination work programs to moderate-risk activities. Examiners are to tailor examination procedures to the size, complexity, and risk profile of an SMB, with examiners focusing on “developing an appropriate assessment of bank management’s ability to identify, measure, monitor, and control risk.”

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