ARTICLE
19 March 2019

FFIEC Agrees To Set Of Principles For All ROEs, OCC To Update ROE Policy

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Cadwalader, Wickersham & Taft LLP

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Federal Financial Institutions Examination Council ("FFIEC") members agreed to a set of principles that apply to all reports of examinations ("ROEs").
United States Finance and Banking

Federal Financial Institutions Examination Council ("FFIEC") members agreed to a set of principles that apply to all reports of examinations ("ROEs"). Separately, the Office of the Comptroller of the Currency ("OCC") said it is reviewing and updating its ROE policy in the " Bank Supervision Process" booklet of the Comptroller's Handbook. Until the OCC updates the "Bank Supervision Process" booklet, the FFIEC ROE principles may be used for any OCC-supervised bank.

The principles provide guidance as to the presentation of information in order to establish consistency, clarity and "ease of reference." According to the FFIEC members, all ROEs should, as applicable:

  • include identifying information, such as, among other things, the name of the agency issuing the ROE and the financial institution's name, location and identifier number;
  • communicate that the ROE has confidential supervisory information;
  • present conclusions and issues in the "order of importance";
  • state the financial institution's condition and risk profile;
  • highlight the sufficiency of the financial institution's risk management practices;
  • document "issues of supervisory concern or warranting corrective action"; and
  • solicit signatures of the board of directors to concede their receipt and review of the ROE.

In addition, the FFIEC policy statement rescinds (i) the "Interagency Policy Statement on the Uniform Core Report of Examination" issued on October 1, 1993, and (ii) OCC Examining Bulletin 1993-7, "Interagency Common Core Report of Examination."

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