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The Federal Reserve Bank of Minneapolis wants to help banks meet our various regulatory, supervisory and operational requirements. One way we help banks is through training. Staff in Supervision, Regulation and Credit (SRC) can share expertise in the areas of safety and soundness supervision; consumer affairs; credit, payments systems risk (PSR) and reserves; and statistical and structural reporting. This article discusses our training and outreach philosophy and the approach the various sections of SRC take to provide such resources. We begin by describing our overall approach. We recognize that there is no single method to assist district member banks, holding companies, account holders and reporting respondents to make sure they have the information needed to ensure compliance with regulations and supervisory guidance. As such, we discuss how we implement that approach across all of our areas of responsibility. Note that the listing below is not an exhaustive set of training opportunities, nor does it replace routine questions and answers that come up in the normal course of business.
Outreach and Training Approach
Regulators and bankers have a common interest in making sure that institutions operate in a safe and sound manner and in compliance with governing laws and regulations. Our priority is to ensure that we communicate effectively with member banks and others, so that they understand regulations and policies and that we continue to build strong partnerships. These efforts take several forms, including formal training sessions, webinars, letters highlighting changes in supervisory expectations, Consumer Compliance Advisory visits and occasionally one-on-one meetings with bank management and staff outside the examination process.
Over the past few years, we have taken several steps to enhance our processes for informing regulated institutions of new or upcoming regulations and current procedures. For example, we began publishing this newsletter. As described in the first quarter 2014 edition of Banking in the Ninth, we created the Relationship Manager (RM) and Consumer Affairs Contact (CAC) programs. These programs allow us to form a more personal relationship with member banks and large holding companies, making sure that questions and concerns can be addressed more directly. Our Consumer Affairs section continues to operate a hotline to address member banks’ Consumer Affairs and Community Reinvestment Act questions. Finally, we hold outreach events, where we meet with member bank and holding company management and provide detail and clarification on regulations and compliance expectations.
Section Specific Training
As detailed below, our Safety and Soundness, Consumer Affairs, Credit/PSR/Reserves and Statistical and Structural Reporting areas all have the ability to help you understand the expectations for your bank.
Safety and Soundness
We use a variety of approaches to answer common questions we receive from organizations regarding Safety and Soundness supervision matters. We reach out via articles in Banking in the Ninth, outreach events and letters supplementing new regulations or supervisory guidance. We also monitor questions that we receive from examiners and institutions regarding the application of regulations and supervisory policies and follow up appropriately. For example, we received a number of questions from institutions about application of the appraisal guidelines. We drafted a letter in response detailing expectations and outlining options for using evaluations. In addition, information technology (IT) specialists have met with institutions one-on-one outside of examinations to help them through IT challenges. Finally, RMs and Relationship Officers (ROs) visit banks and work with management and staff to make sure they understand our expectations. The RMs and ROs also talk through issues and concerns of assigned banks, bank holding companies and savings and loan holding companies via telephone if that better fits the needs of institutions. They welcome input on concerns affecting member banks and holding companies.
Safety and Soundness staff can provide training and insight to bank management and boards of directors in other ways, including:
- A half-day director training program is offered, which includes the following modules:
- Characteristics of an effective director
- Interest rate risk
- Liquidity
- Compliance risk management
- Interactive case study
We conduct director training for directors of multiple institutions at a central location or, with sufficient notice, we can work with institutions to provide training to a full board.
- RMs, risk specialists and other SRC staff are available to discuss supervisory guidance in more detail on the full range of safety and soundness issues either in person or by telephone. With advance notice, safety and soundness staff can meet with bank management and staff to discuss new guidance and regulations or to answer questions regarding specific areas of concern as well as to provide general information about supervisory expectations.
Consumer Affairs
We know that Consumer Affairs regulations and expectations can be highly technical and challenging for many institutions, particularly smaller ones. As a result, we offer our Consumer Affairs Assistance Hotline, and larger or more complex institutions have assigned CACs. In addition, banks can request an advisory visit, which is a non-examination visitation, frequently focused on assisting with implementation of specific regulations. Advisory visits are conducted subject to Reserve Bank and bank staff availability. Compliance examiners can address bankers’ questions and review materials on specific compliance requirements or general risk management expectations through these tools.
Other ways our Consumer Affairs section has been willing to help banks include:
- Working individually with banks during their risk assessment or implementation of major changes in products or operations, including providing suggestions for risk management. In most cases, we’ll work with a bank remotely, but we could visit the bank if needed.
- Providing training on compliance requirements to groups of banks or compliance officers. We provide training through conference calls, webinars or meetings in person, depending on staff availability.
- Meeting with management and/or directors to discuss their roles and responsibilities in compliance risk management. This training may involve a presentation or a less formal meeting conducted either via conference call or in person, depending on staff availability.
Credit/PSR/Reserves
Our Credit/PSR/Reserves section provides assistance to all depository institutions that maintain accounts at the Reserve Bank, those that have collateral pledged to the Federal Reserve and other reporting respondents. We can provide broadcast and/or individual training on
- Federal Reserve master account management
- Account establishment, maintenance and monitoring, and monitoring tools
- Reserve requirement management
- Requirement calculation and compliance, position monitoring and monitoring tools
- Discount window and payments system risk collateral management
- Discount window lending programs, daylight overdraft and overnight credit extensions, and collateral eligibility, pledging and valuation
Generally, we provide assistance based on telephone inquiries initiated by potential or existing depository institution customers; however, when significant changes in processes or policies occur, we send letters to affected institutions (either broad-based or institution-specific), conduct webinars or consider other methods for ensuring that institutions have a clear understanding of new requirements.
Statistical and Structural Reporting
Our Statistical and Structural Reporting staff are eager to support reporting institutions. Most reporting institutions prefer telephone consultations, but staff are flexible in providing help. The statistics staff routinely notifies Ninth District respondents when various webinars or modules clarifying or providing training on FR2900 and “Y” series reports are available.
Conclusion
All sections within SRC are available to answer inquiries on specific issues or address concerns of district member banks, account holders and report filers. The Federal Reserve Bank of Minneapolis wants to make sure that you have the tools and resources you need to understand regulations and requirements prior to exams, reviews and ratings. Our goal is to help banks operate safely, soundly and in compliance with laws and regulations. If you have a concern, a topic or an issue you need more assistance with, contact your RM, CAC, Credit/PSR/Reserves or Statistical and Structural Reporting analyst, or go to mpls.src.outreach@mpls.frb.org.
