[HMDA Guy 78]

We are preparing for an upcoming FDIC Compliance examination, and want to go over some basic exam management thoughts with our branch and commercial lenders. Does anyone have any recommendations for general information they provide their lending teams as far as how and when to appropriately answer examiner questions, if asked directly? The Compliance Department will, of course, make all attempts to monitor interaction between bank personnel and examiners – just trying to adequately prepare our team.

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[jholzknecht]

I believe the best advice for your team is to provide honest answers without elaboration. Most examiners ask questions to gather information needed to thierr job, without intention to deceive. It is also helpful if team members report any conversations with examiners to compliance so mitigation efforts can begin, when needed.

For example: the examiner asks, “When is uthe application disclosure for an ARM loan provided.” The team member responds, “At application.” The answer is truthful and contains no elaboration, but the more correct answer would have been, “We provide the disclosure at the time we provide the applicant with the application form.” Follow up with the examiner to clarify the exact timing might prevent a problem.

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