Community Bankers Association of Illinois

CBAI Survey on Harshness of Bank Examinations


Survey will be submitted to:

Please check the most accurate response to Items #1 through #7 and, at your discretion, add any additional comments in response to Item #8 if you choose to do so. Following the responses to Items #2 through #7, you can add any additional comments if you believe that the response that you checked needs further amplification. Please do not provide any comments in response to any Item that might disclose “confidential supervisory information” such as specific examination results, examiners’ comments, CAMELS ratings, etc.
Item #1. What type of charter does your financial institution have?

STATE BANK   NATIONAL BANK    STATE SAVINGS BANK    STATE SAVINGS & LOAN ASSOCIATION    FEDERAL SAVINGS & LOAN ASSOCIATION/FEDERAL SAVINGS BANK

Item #2. Has your financial institution been examined by a State or federal bank regulatory agency since January 1, 2008?
If “NO,” you may disregard the remainder of this survey.

YES   NO  

Additional Comments:  

Item #3. If the answer to Item #2 was “YES,” which agency conducted the examination? [If there was a joint examination or multiple examinations involving more than one agency, please check all responses that apply.]

STATE OF ILLINOIS    OCC   FDIC   OTS   FEDERAL RESERVE (CHICAGO)    FEDERAL RESERVE (ST. LOUIS)

Additional Comments:  

Item #4. In your opinion, has the personal/professional demeanor, attitude, etc. of the bank examiners been the same as it was when examinations were conducted prior to 2008?

YES, IT HAS BEEN SIMILAR TO EXAMINATIONS IN PRIOR YEARS

NO, IT HAS BEEN MORE AGGRESSIVE OR CONFRONTATIONAL THAN IN PRIOR YEARS

NO, IT HAS BEEN MORE COOPERATIVE AND HELPFUL THAN IN PRIOR YEARS

I/WE HAVE NOT FORMED AN OPINION REGARDING THEIR DEMEANOR, ATTITUDE, ETC.

Additional Comments:  

Item #5. Is it your opinion that the regulatory examiners “had an agenda” or were otherwise directed by their regulatory agencies to be harsher or more aggressive in the conduct of the examination or in the examination findings/results?

YES, I EITHER KNOW OR BELIEVE THAT THE EXAMINERS APPROACHED THE EXAMINATION WITH THE INTENTION OF BEING HARSHER OR MORE AGGRESSIVE

NO, THE EXAMINERS WERE NOT HARSHER OR MORE AGGRESSIVE AND SO THE PREMISE OF THIS ITEM #5 IS NOT CORRECT

NO, IF THE EXAMINERS WERE MARGINALLY HARSHER OR MORE AGGRESSIVE THAN PREVIOUS EXAMINATIONS IT COULD HAVE BEEN DUE TO RANDOM FACTORS

I/WE HAVE NOT FORMED AN OPINION REGARDING WHETHER, OR WHY, EXAMINERS WERE HARSHER OF MORE AGGRESSIVE

Item #6. In general (without specifying particular examination findings, recommendations or instructions from examiners), based on your experience in your banking market did the regulatory examiners make reasonable assumptions about your financial institution’s need to re-assess or to write down the value of assets, to increase the Allowance for Loan and Lease Losses, to raise additional capital, or to make other substantial changes to the financial structure of the bank or of its asset portfolios?

YES, BASED ON MY/OUR EXPERIENCE THE EXAMINERS’ ASSUMPTIONS, CONCLUSIONS AND INSTRUCTIONS WERE REASONABLE

NO, BASED ON MY/OUR EXPERIENCE THE EXAMINERS’ ASSUMPTIONS, CONCLUSIONS AND INSTRUCTIONS WERE UNREASONABLY PESSIMISTIC, NEGATIVE OR DEMANDING

NO, BASED ON MY/OUR EXPERIENCE THE EXAMINERS’ ASSUMPTIONS, CONCLUSIONS AND INSTRUCTIONS WERE UNREASONABLY GENEROUS OR POSITIVE

I/WE HAVE NOT FORMED AN OPINION REGARDING THE EXAMINERS’ ASSUMPTIONS, CONCLUSIONS AND INSTRUCTIONS

Item #7. In general (without specifying particular examination findings, recommendations or instructions from examiners), based on your experience in your banking market would the examiners’ assumptions, conclusions or instructions be detrimental to your financial institution’s ability to be a successful institution?

YES, THE EXAMINERS’ ASSUMPTIONS, CONCLUSIONS AND INSTRUCTIONS COULD REALISTICALLY PLACE A BURDEN ON OUR FINANCIAL INSTITUTION THAT MAKES IT MORE DIFFICULT FOR US TO BE SUCCESSFUL

NO, THE EXAMINERS’ ASSUMPTIONS, CONCLUSIONS AND INSTRUCTIONS WERE REASONABLE AND WILL NOT CONTRIBUTE TO ANY SUCCESS OR TO ANY PROBLEMS THAT OUR FINANCIAL INSTITUTION MAY ENCOUNTER

NO, EVEN IF THE EXAMINERS’ ASSUMPTIONS, CONCLUSIONS AND INSTRUCTIONS WERE QUESTIONABLE THEY WILL HAVE NO IMPACT ON THE ABILITY OF OUR FINANCIAL INSTITUTION TO BE SUCCESSFUL

I/WE HAVE NOT FORMED AN OPINION REGARDING THE IMPACT OF THE EXAMINERS’ ASSUMPTIONS, CONCLUSIONS AND INSTRUCTIONS ON THE FUTURE SUCCESS OF OUR FINANCIAL INSTITUTION

Additional Comments:  

Item #8. Without disclosing any specific regulatory findings relating to examinations or examination reports (for example, CAMELS ratings or specific comments from examiners that might constitute “confidential supervisory information”), please add any additional general comments that might help CBAI to understand whether (or to what degree) the tone, scope, conclusions or effects of recent examination(s) should be a legitimate concern for Illinois’ community banks, savings and loan associations and savings banks.

Additional Comments:  

The Community Bankers Association of Illinois thanks you for your time and for your continuing commitment to your communities and to the cause of community banking.


 
800.736.2224 (IL) | 217.529.2265