Assistance in Responding to Regulatory Orders




I. Examples



Assistance to Regulatory Orders

I. Examples

Our consultants have extensive experience in assisting banks and credit unions in responding to regulatory orders or criticisms.

Some of the examples of how our team has helped institutions include

  • Performing independent management assessments to evaluate the adequacy of the leadership skills, staffing levels, policies and procedures, and culture of an institution to operate in a safe and sound manner. Our consultants have performed over 30 of these assessment both in reaction to a directive issued by an examiner after a safety and soundness exam or requested by the Board of Directors after an institution received significant criticisms in a recent regulatory exam or the institution was having a lot of internal turmoil in the organization.
  • Served in the capacity of temporary CEO or worked hand in hand with the Board of Directors after developing a plan to turn around both banks and credit unions. In all cases, the institutions were under Prompt Corrective Action (PCA) orders and needed a plan to improve the institution’s net earnings in a very short time period or the institution would be taken over by the either the FDIC or NCUA. Actions taken included:
    • Renegotiating larger vendor contracts to obtain expense concessions.
    • Eliminating staff and or certain benefit plans for senior executives.
    • Negotiating a reduced pay-off of debt at the holding company level.
    • Eliminating trust preferred security debt at the holding company level.
    • Negotiating the sale of branches for gains.
    • Paying off advances or other debt.
    • Renegotiate terms of loans to improve the quality of the credit or at least the adequacy of the collateral pledged against the debt to eliminate the need or reduce the amount of a specific reserve established for a loan.
    • Was able to return the institution to being considered well capitalized or obtain a buyer for the bank that generated significant net proceeds for the sellers.
  • Assist banks and credit unions in addressing recommendations in regulatory exam reports.
  • Rewrite or author various policies and procedures for institutions to alleviate criticisms coming from regulatory exams.

We have the unique experience of consulting with the regulatory agencies during both the savings and loan crisis in the late 1980’s early 1990’s and the recent economic crisis of 2008 through 2012. We understand what caused banks and credit unions to fail and what the examiners want to see in terms of changes to prevent them from taking further action. Call us, we can help!