The regulatory environment poses a major challenge for the banking community. Regulators wield tremendous power — with few checks and balances — and the confidential nature of bank exams makes it difficult to pinpoint accountability. As a remedy, the Indiana Bankers Association has joined with bank trade associations nationwide to create the Regulatory Feedback Initiative (RFI), designed to bring transparency and accountability to the regulatory process, and to help every bank in the country prepare for examinations and manage regulatory risk. View RFI video.
The initiative consists of an anonymous online survey for every bank to take immediately following each examination. This process allows the Coalition of Bankers Associations to track regulatory practices, state-to-state and regulator-to-regulator. Identifying inconsistencies and misguided regulatory treatment is more important now than ever, given the avalanche of new regulations required by the Dodd-Frank Act.
The survey is administered by Allegiance Inc., an independent third party with a track record of collecting anonymous feedback from bank customers and employees. The survey is anonymous and, because the data is available only in aggregate form, results cannot be tracked back to any participating institution.
The resulting database of examination experiences creates a powerful resource for the entire industry, allowing for customized exam preparation reports for individual banks. Each report includes a summary of all the reports filed by similarly situated banks (asset size, primary regulator, region, etc.) to compare experiences.
The database also is a tool for identifying regulatory problems as they occur, so IBA and other state associations can work with regulatory agencies to make necessary changes in the examination process. We have met with the regulatory agencies, which have reviewed the surveys and are interested in the information they provide.
More information about the initiative is available at the Coalition of Bankers Associations website, including paper copies of the survey for advance preparation before completing the survey online. This regulatory feedback initiative is a long-term endeavor that will become a vital part of IBA's efforts to improve the regulatory environment for our member banks. We hope you will integrate this survey into your regulatory process. For questions or more information, please contact Rod Lasley at the IBA, 317-387-9380. Hoosier Banker RFI article.