Federal Financial Institutions Examination Council

A N N U A L R E P O R T 2010

Board of Governors of the System, Federal Deposit Insurance Corporation, National Credit Union Administration, Offi ce of the Comptroller of the Currency, Offi ce of Thrift Supervision, State Liaison Committ ee

Pantone 646-75% Federal Financial Institutions Examination Council

A N N U A L R E P O R T 2010

Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, Office of Thrift Supervision, State Liaison Committee MEMBERS OF THE COUNCIL

Sheila C. Bair, Chairman John E. Bowman, Vice Chairman Debbie Matz Chairman Acting Director Chairman Federal Deposit Insurance Corporation Office of Thrift Supervision National Credit Union Administration

John Walsh Daniel K. Tarullo John Munn Acting Comptroller of the Currency Member, Board of Governors of the Director, Nebraska Department of Office of the Comptroller of the Currency Federal Reserve System Banking & Finance LETTER OF TRANSMITTAL

Federal Financial Institutions Examination Council Arlington, VA 22226 March 31, 2011

The President of the Senate The Speaker of the House of Representatives

Pursuant to the provisions of section 1006(f) of the Financial Institutions Regulatory and Interest Rate Control Act of 1978 (12 U.S.C. § 3305), I am pleased to submit the 2010 Annual Report of the Federal Financial Institutions Examination Council.

Respectfully,

Sheila C. Bair Chairman TABLE OF CONTENTS

vii Message from the Chairman 1 Overview of the Federal Financial Institutions Examination Council Operations 3 Record of Council Activities 5 State Liaison Report 7 Activities of the Interagency Staff Task Forces 21 The Federal Regulatory Agencies and their Supervised Institutions 29 Assets, Liabilities, and Net Worth of U.S. Commercial Banks, Thrift Institutions, and Credit Unions as of December 31, 2010 30 Income and Expenses of U.S. Commercial Banks, Thrift Institutions, and Credit Unions for Twelve Months Ending December 31, 2010 31 Appendix A: Relevant Statutes 37 Appendix B: 2010 Audit Report 47 Appendix C: Maps of Agency Regions and Districts 53 Appendix D: Organizational Listing of Personnel

v MESSAGE FROM THE CHAIRMAN

While the recent financial crisis tion risks associated with these technically ended in 2010, the slow products. economic recovery and the fail- • Released an advisory that ure of 157 banks last year reflect reminded institutions of super- that the FFIEC continues to have visory expectations for sound a vital role in maintaining the sta- practices to manage interest bility of the financial industry. The rate risk (IRR). This advisory, FFIEC has remained on the fore- adopted by each of the financial front of major policy initiatives regulators, reiterates the impor- that prescribe uniform principles, tance of effective corporate standards, and report forms for the governance, policies and proce- federal examination of financial dures, risk measuring and mon- institutions by its member agen- itoring systems, stress testing, cies. The FFIEC also continued to and internal controls related to foster communication, cooperation, the IRR exposures of depository and coordination among mem- institutions. ber agencies and the State Liaison Committee that make up the Coun- • Facilitated interagency guid- cil, and its task forces, including ance on correspondent con- interagency efforts to address cer- centration risks that outlines tain provisions of the Dodd-Frank expectations for identifying, Sheila C. Bair and Consumer monitoring and managing cor- Protection Act of 2010 (the Dodd- respondent concentration risks Frank Act). between financial institutions. The guidance also addresses I am pleased to report that the expectations for performing FFIEC continued to meet its mis- appropriate due diligence on all sion of promoting uniformity in credit exposures to, and fund- the supervision of financial institu- ing transactions with, other tions in 2010. Details on the 2010 financial institutions. achievements are included later in this report in the Record of Coun- • Facilitated the development cil Activities and Activities of the and publication of final inter- Interagency Staff Task Forces. I agency guidance to provide would like to recognize, however, sound practices for manag- some of the more significant ini- ing funding and liquidity risk tiatives that the Council, its task and strengthening liquidity forces, and interagency working risk-management practices. groups facilitated during the year: The guidance emphasizes the importance of cash flow pro- • Released guidance on reverse jections, diversified funding mortgage products. The guid- sources, stress testing, a cushion ance, adopted by each of the of liquid assets and a formal, financial regulators, emphasizes well-developed contingency the consumer protection con- funding plan as primary tools cerns raised by reverse mort- for measuring and managing gages and the importance of liquidity risk. financial institutions mitigat- ing the compliance and reputa- • Issued updated guidance for

vii examiners, financial institu- agencies through training spon- in July 2010. These revisions tions, and technology service sored by the FFIEC’s Examiner will become effective on March providers on the risks associ- Education Office. 31, 2011, upon approval from ated with retail payment sys- the Office of Management and • Offered a number of well- tems. The Retail Payment Budget. received training sessions for Systems Booklet provided guid- examiners, including several ance on the risks and risk-man- As evidenced by the foregoing ini- on analyzing credit risk. Also agement practices applicable to tiatives, the FFIEC continues to do designed and piloted a new financial institutions’ retail pay- important work—thanks to the course on distressed commercial ment systems activities, includ- dedicated and talented full-time real estate and a second pilot on ing checks, electronic payments Council staff, as well as task force structured finance. related to credit cards and debit representatives from all the mem- ber agencies. Even though great cards, and the automated clear- • Announced improvements in ing house. progress was made throughout the production and distribution 2010, we have much more work to • Facilitated the development of the Uniform Bank Perfor- do in the coming year, including and issuance of interagency mance Report (UBPR) by tran- the implementation of the SAFE appraisal and evaluation sitioning these processes to the Act in 2011 and the requirements guidelines that reflect devel- interagency Central Data Repos- imposed on the member agencies opments regarding apprais- itory (CDR). These improve- by the Dodd-Frank Act. Despite als and evaluations as well as ments facilitated the availabil- these challenges, the FFIEC con- changes in appraisal standards ity of UBPR data and reports to tinues to provide a forum for the and advancements in regulated bankers, bank supervisors, and regulators to act—in a strong and institutions' collateral valuation the general public through the unified voice and in a timely fash- methods. CDR Public Data Distribution ion—on supervisory policy issues Website. that are relevant and of critical • Released the revised FFIEC importance. I am, indeed, honored /Anti-Money • Published various revisions to to have served as its Chairman for Laundering (BSA/AML) Exam- the Reports of Condition and the last two years. ination Manual. Income, including changes to reflect the permanent increase • Trained over 2,500 state and in the deposit insurance limit federal employees from various to $250,000 that was enacted

viii OVERVIEW OF THE FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL OPERATIONS

The Federal Financial Institu- Insurance Corporation and the appraisals in connection with tions Examination Council (FFIEC Board of Governors of the Federal federally related transactions; or Council) was established on Reserve System. Correspondingly, (2) monitoring the appraisal stan- March 10, 1979, pursuant to title X in accordance with the Dodd- dards established by the federal of the Financial Institutions Regu- Frank Act, the Director of the financial institution regulatory latory and Interest Rate Control newly created Consumer Finan- agencies and the former Resolu- Act of 1978 (FIRIRCA), Public cial Protection Bureau will join the tion Trust Corporation; (3) main- Law 95-630. The purpose of title membership of the Council. taining a national registry of X, cited as the Federal Financial appraisers who are certified and Institutions Examination Council The Council is responsible for licensed by a state, and are also Act of 1978, was to create a formal developing uniform reporting eligible to perform appraisals in interagency body empowered to systems for federally supervised federally related transactions; and prescribe uniform principles, stan- financial institutions, their holding (4) monitoring the practices, pro- dards, and report forms for the companies, and the nonfinancial cedures, activities, and organiza- federal examination of financial institution subsidiaries of those tional structure of the Appraisal institutions by the Board of Gov- institutions and holding compa- Foundation, a nonprofit educa- ernors of the Federal Reserve Sys- nies. It conducts schools for exam- tional corporation established tem, the Federal Deposit Insurance iners employed by the five fed- by the appraisal industry in the Corporation, the National Credit eral member agencies represented United States. Union Administration, the Office on the Council and makes those of the Comptroller of the Currency, schools available to employees of Title V of the Housing and Eco- and the Office of Thrift Supervi- state agencies that supervise finan- nomic Recovery Act of 2008 estab- sion and to make recommenda- cial institutions. lished the responsibility for the tions to promote uniformity in the The Council was given additional federal banking agencies, through supervision of financial institu- statutory responsibilities by sec- the FFIEC and in conjunction with tions. To encourage the application tion 340 of the Housing and Com- the Farm Credit Administration, of uniform examination principles munity Development Act of 1980, to develop and maintain a system and standards by the state and Public Law 96-399. Among these for registering depository insti- federal supervisory authorities, responsibilities are the implemen- tution employees as registered the Council established, in accor- tation of a system to facilitate pub- loan originators with the Nation- dance with the requirement of the lic access to data that depository wide Mortgage Licensing System statute, an advisory State Liaison institutions must disclose under and Registry (NMLSR). The sys- Committee. In accordance with the Home Mortgage Disclosure Act tem shall, at a minimum, furnish the Financial Services Regulatory of 1975 (HMDA) and the aggrega- or cause to be furnished to the Relief Act of 2006, a representa- tion of annual HMDA data, by cen- NMLSR information concerning tive state regulator was added as sus tract, for each metropolitan sta- the employees’ identity, including: a voting member of the Council in tistical area. (A) fingerprints for submission to October 2006. The Council will see the Federal Bureau of Investiga- a change in July 2011 according to Title XI of the Financial Institutions tion and any governmental agency the provisions of the Dodd-Frank Reform, Recovery, and Enforce- or entity authorized to receive Wall Street Reform and Consumer ment Act of 1989 established the such information for a state and Protection Act of 2010 (Dodd- Appraisal Subcommittee within national criminal history back- Frank Act) which closes the Office the Council. The functions of the ground check; and (B) personal of Thrift Supervision and transfers subcommittee are (l) monitor- history and experience, includ- most of its functions to the Office ing the requirements, including a ing authorization for the NMLSR of the Comptroller of the Currency. code of professional responsibility, to obtain information related to Certain other authorities of the established by states for the certi- any administrative, civil, or crimi- Office of Thrift Supervision will be fication and licensing of individu- nal findings by any governmental transferred to the Federal Deposit als who are qualified to perform jurisdiction.

1 The Council has six members, • Information Sharing The Council’s activities are and in 2010 it was comprised of funded in several ways. Most of • Reports a member of the Board of Gover- the Council’s funds are derived nors of the Federal Reserve System • Supervision from assessments on its five fed- appointed by the Chairman of the eral member agencies. It receives Board, the Chairman of the Federal • Surveillance Systems tuition fees from non-agency Deposit Insurance Corporation, The Council also established the attendees to cover some of the the Chairman of the Board of the Legal Advisory Group, composed costs associated with its examiner National Credit Union Administra- of the general or chief counsel of education program. The Council tion, the Comptroller of the Cur- each of the member agencies, to also receives reimbursement for rency, the Director of the Office of provide support to the Council the services it provides to support Thrift Supervision, and the Chair- and staff in the substantive areas preparation of the quarterly Uni- man of the State Liaison Commit- of concern. The task forces and the form Bank Performance Report. tee. To effectively administer the Legal Advisory Group provide In 2010, the Federal Reserve Board full spectrum of projects in all its research and develop analytical provided budget and account- functional areas, including but papers and proposals on the issues ing services to the Council. The not limited to researching future that the Council addresses. In Council is supported by a small, enhancements for reporting, addition, the Council established full-time administrative staff in its training products, and guidance the Agency Liaison Group, com- operations office and in its exam- the Council established six staff posed of senior officials respon- iner education program, which task forces. The task forces are sible for coordinating the efforts are located at the Council’s exam- each comprised of six senior of their respective agencies’ staff iner training facility in Arlington, officials, drawn from the five members. Virginia. Each Council staff mem- federal member agencies and a ber is detailed from one of the five representative of the State Liai- member agencies represented on son Committee; each are tasked Administration of the Council the Council but is considered an with one of the following subject The Council holds regular meet- employee of the Council. matters: ings at least twice a year. It holds • Consumer Compliance other meetings whenever called by the Chairman or three or more • Examiner Education Council members.

2 RECORD OF COUNCIL ACTIVITIES

The Federal Financial Institutions Examination Council in session.

The following section is a chrono- interagency awards program not later than April l of each year, logical record of the official actions that recognizes individuals of the the Council publish an annual taken by the FFIEC during 2010 member agencies who have pro- report covering its activities dur- pursuant to the Federal Financial vided outstanding service to the ing the preceding year. Institutions Examination Council Council on interagency projects Act of 1978, as amended, and the and programs during the previous Home Mortgage Disclosure Act year. March 18, 2010 (HMDA). Action. Approved Appraisal March 12, 2010 Subcommittee Chair, Debo- February 16, 2010 rah S. Merkle, Office of Thrift Action. Approved the 2009 annual Supervision. Action. Approved the issuance of report of the Council to the the Council’s annual interagency Congress. Explanation. The Council is awards. required to approve the selection Explanation. The legislation estab- of the Appraisal Subcommittee Explanation. The Council has an lishing the Council requires that, Chair, who serves a two-year term.

3 March 18, 2010 Action. Approved Re-Appointment of State Liaison Committee Mem- ber, Sarah Bloom Raskin, Mary- land Office of Financial Regulation Commissioner. Explanation. The Council must approve two of the State Liaison Committee members—those who do not officially represent the Con- ference of State Banking Super- visors, the American Council of State Savings Supervisors, or the National Association of State Credit Union Supervisors.

March 26, 2010 Action. Approved the appointment of six task force chairs. Chairman Bair engaged in discussions during the November 2010 Council meeting. Explanation. The chairs for all six standing task forces are approved annually and are drawn from man- including the EFOIA of 1996 and Explanation. The Council is agement and staff of the five fed- the Open Government Act of 2007. required to approve the annual eral member agencies and rep- The FFIEC FOIA regulation has budget that funds the Council's resentatives of the State Liaison been in effect since 1980 and was staff, programs, and activities. Committee. last amended in 1988. The Council approved the proposed revisions December 30, 2010 April 9, 2010 and the final updated regulation was published in the Federal Regis- Action. Approved Memorandum Action. Approved the Central Data ter in December 2010. of Understanding (MOU) by and Repository (CDR) Steering Com- between the FFIEC, Board of Gov- mittee’s Task Order #6. ernors of the Federal Reserve Sys- October 27, 2010 Explanation. The Council is required tem, Federal Deposit Insurance to approve task orders that exceed Action. Approved New State Liai- Corporation, Office of the Comp- a specific dollar amount. Task son Committee Member, David troller of the Currency, and Office Order #6 covers funds for CDR Cotney, the Massachusetts Division of Thrift Supervision regarding the enhancements to improve Call of Banks Acting Commissioner. management and funding of the Central Data Repository (CDR). Report processing, public data dis- Explanation. The Council is required tribution, and Uniform Bank Per- to approve two of the State Liaison Explanation. The CDR is an ongo- formance Report processing. Committee members—those who ing FFIEC project and during 2010 do not officially represent the Con- production of the Uniform Bank July 8, 2010 ference of State Bank Supervisors, Performance Report (UBPR) was the American Council of State Sav- added to the CDR. In order to sim- Action. Approved proposed revi- ings Supervisors, or the National plify oversight of CDR operations sions to the FFIEC’s Freedom of Association of State Credit Union the governing MOU was rewritten Information Act (FOIA) regulation. Supervisors. to incorporate the UBPR. That new Explanation. The Legal Advisory MOU supersedes and replaces the CDR MOU dated August 2007 and Group of the Council recognized November 22, 2010 the need to update its FOIA regula- the UBPR MOU dated March 2009. tion pursuant to significant amend- Action. Approved the 2011 Council ments to the FOIA since 1988, budget.

4 STATE LIAISON REPORT

John Munn, Chairman David Cotney, Harold E. Feeney Director, Nebraska Commissioner, Massachusetts Commissioner, Texas Department of Banking & Finance Division of Banks Credit Union Department

The State Liaison Committee con- sists of five representatives of state regulatory agencies that supervise financial institutions. The repre- sentatives are appointed for two- year terms. A State Liaison Com- mittee member may have his or her two-year term extended by the appointing organization for an additional, consecutive two-year term. Each year, the State Liaison Committee elects one of its mem- bers to serve as chair for twelve months. The Council elects two of the five members. The American Council of State Savings Supervi- sors, the Conference of State Bank Supervisors and the National Association of State Credit Union Douglas Foster, Charles A. Vice Supervisors designate the other Commissioner, Texas Commissioner, Kentucky three members. Department of Savings and Mortgage Lending Department of Financial Institutions

5 The Financial Services Regulatory range of important regulatory federal supervisory efforts, the Relief Act of 2006 made the Chair- subjects; reflecting the spirit and State Liaison Committee contin- man of the State Liaison Com- intent of Congress in establishing ues to encourage state regulatory mittee, currently John Munn, the the State Liaison Committee. The authorities to adopt and imple- Director of Banking and Finance Conference of State Bank Supervi- ment those policies, guidelines, of the Nebraska Department of sors serves as the primary liaison and examination procedures Banking and Finance, a voting to the FFIEC for all administrative adopted by the Council. member of the council. With the matters. passage of this act, the State Liai- In 2010, David Cotney, Commis- In response to their role on the son Committee appointed state sioner of the Massachusetts Divi- Council, the State Liaison Com- supervisors to represent the state sion of Banks, became the first mittee meets in person before each system on FFIEC task forces and State Liaison Committee represen- Council meeting to review the working groups. The State Liaison tative to chair an FFIEC task force agenda and discuss topics of inter- Committee’s involvement with when he was elected chair of the est which may come before the such groups enables state regu- Consumer Compliance Task Force Council. lators to participate in substan- in April. tive policy discussions on a broad In addition, to further state-

6 ACTIVITIES OF THE INTERAGENCY STAFF TASK FORCES

Task Force on Act (HMDA)/CRA Data Col- revised questions and answers. Consumer Compliance lection Subcommittee. The task These Questions and Answers force also creates ad hoc working (Q&As) consolidate and supersede The Task Force on Consumer groups to handle particular proj- all previously published Inter- Compliance promotes policy coor- ects and assignments. The task agency Q&As on the CRA and dination, a common supervisory force meets monthly to address were effective immediately. The approach, and uniform enforce- and resolve common issues in new question provides examples ment of consumer protection laws compliance supervision. While of how to demonstrate that com- and regulations. The task force significant issues or recommen- munity development services identifies and analyzes emerging dations are referred to the FFIEC meet the criteria of serving low- consumer compliance issues and for action, the FFIEC has dele- and moderate-income areas and develops proposed policies and gated to the task force the author- people. The revised Q&As enable procedures to foster consistency ity to make certain decisions and consideration of a pro rata share of among the agencies. Addition- recommendations. mixed-income affordable housing ally, the task force reviews legisla- projects as community develop- tion, regulations, and policies at ment projects. the state and federal level that may Initiatives Addressed in 2010 have a bearing on the compliance At the end of May 2010, the fed- responsibilities of the five federal CRA Subcommittee Activities eral banking and thrift agencies member agencies. approved via notational vote the After considering comments 2010 List of Distressed or Under- During 2010, the task force received on proposed CRA ques- served Nonmetropolitan Middle- used two standing subcommit- tions and answers that were pub- Income Geographies where revi- tees to help promote its mission: lished in January 2009, the fed- talization or stabilization activities the Community Reinvestment eral banking and thrift agencies will receive CRA consideration Act (CRA) Subcommittee and adopted on March 11, 2010 one as community development. The the Home Mortgage Disclosure new question and answer and two agencies issued the list on June 1, 2010.

HMDA/CRA Data Collection Subcommittee Activities The HMDA and CRA Data Collec- tion System re-architecture initia- tive was completed on schedule and on budget. Benefits associ- ated with the HMDA/CRA 2010 re-architecture initiative relative to the current mainframe system include reduced data reporting and processing costs and enhanced agency access to updated HMDA and CRA data. The project was completed on June 30, 2010. The task force voted to approve the 2011 budget for HMDA and Task Force on Consumer Compliance meeting. CRA on September 9, 2010 and

7 presented to the Council for 2010) and the Higher Education counseling to consumers consider- approval. Opportunity Act (effective date ing these products; and to avoid February 14, 2009). potential conflicts of interest. The On November 10, 2010, the task guidance also addresses related On June 10, 2010, the task force force approved by notational vote policies, procedures, and inter- approved amended Regulation Z to gather and publish American nal controls and third-party risk examination procedures to incor- Community Survey (ACS) data management. from the U.S. Census Bureau for porate revisions for open-end HMDA and CRA purposes every transactions (effective date July 1, five years. More frequent updates 2010). Flood Insurance will affect the geographic income In 2009, the FFIEC agencies, along levels used for CRA examinations, Regulation E with the Farm Credit Administra- which to-date have only been (Electronic Fund Transfers) tion, proposed and solicited public updated every ten years. comments on additional questions On June 10, 2010, the task force and answers regarding insurable approved examination procedures value and force placement issues. Fair Credit Reporting Act (FCRA) to incorporate changes to Regu- During 2010, the task force com- lation E covering gift cards and On February 18, 2010, the task pleted its review of the comments. overdraft fees for ATM and one- force approved examination pro- Final action on certain proposed time debit card transactions. The cedures corresponding to the questions and answers is expected revised procedures also refer to regulation implementing Sections in early 2011 while additional each agency's existing overdraft 623(a)(8) and 623(e) of the FCRA comment may be sought on guidance and include the Board regarding the duties of furnish- some proposed questions and of Governors of the Federal ers of information to a consumer answers. reporting agency. The rule com- Reserve System’s (Federal Reserve monly known as the “furnisher Board) recent clarifications to Reg- rule” promotes the accuracy and ulation E (effective date July 1, integrity of information furnished 2010). Task Force on to credit bureaus and other con- Examiner Education sumer reporting agencies. The Regulation DD (Truth in Savings) The Task Force on Examiner Edu- effective date of the furnisher rule cation is responsible for oversee- was July 1, 2010. On July 2, 2010, the task force approved via notational vote ing the FFIEC’s examiner edu- On November 9, 2010, the task examination procedures which cation program on behalf of the force approved examination pro- were amended to reflect technical Council. The task force promotes cedures corresponding to the clarifications provided by the Fed- interagency education through regulation implementing Section eral Reserve Board. timely, cost-efficient, state-of-the- 615(h) of the FCRA involving the art training programs for agency duties of institutions that use con- Reverse Mortgages examiners and staff. The task force sumer report information for risk- develops programs on its own ini- based pricing purposes in exten- On August 18, 2010, the FFIEC tiative and in response to requests sions of credit. The rule requires agencies published final reverse from the Council or other Coun- creditors to provide consumers mortgage guidance in the Federal cil task forces. Each fall, task force with a “risk-based pricing” notice. Register entitled Reverse Mortgage staff prepares a training calendar The effective date of the risk- Products: Guidance for Managing based on demand from the five based pricing rule was January 1, Compliance and Reputation Risks. federal member agencies and state 2011. The final guidance discusses the financial institution regulators. general features of, certain legal Based on this demand, task force Regulation Z (Truth in Lending) provisions applicable to, and con- staff schedules, delivers, and eval- sumer protection concerns raised uates training programs through- On February 18, 2010, the task by reverse mortgage products. out the year. In 2010, the number force approved amended Regu- In addition, the guidance focuses of people that attended task force- lation Z examination procedures on the need to provide adequate sponsored training totaled 2,562 to incorporate revisions made to information to consumers about (see the table on page 10 for details Regulation Z by the Credit Card reverse mortgage products; to of participation by program and Act (effective date February 22, provide qualified independent agency).

8 Federal Deposit Insurance Corpo- ration’s Seidman Center in Arling- ton, Virginia. This facility offers convenient access to two auditori- ums and numerous classrooms.

Course Catalogue and Schedule The course catalogue and sched- ule are available online at www. ffiec.gov/exam/education.htm. Additionally, a printed copy of the 2011 course catalogue and sched- ule are available from the EEO. To obtain a copy, contact:

Karen K. Smith, Manager FFIEC Examiner Education Office Task Force on Examiner Education meeting. 3501 Fairfax Drive Room B-3030 Arlington, VA 22226-3550 Initiatives Addressed in 2010 nation Handbook continue to Phone: (703) 516-5588 The Task Force on Examiner Edu- be available to examiners and cation has continued to ensure the industry through the FFIEC that the FFIEC’s educational pro- Website. Task Force on grams meet the needs of agency Information Sharing personnel, are cost–effective, and are widely available. The task force Facilities The Task Force on Information meets monthly with the Exam- Sharing promotes the sharing of FFIEC rents office space, class- electronic information among iner Education Office (EEO) staff rooms, and lodging facilities at the to discuss emerging topics, to review feedback from each course and conference, and to develop a framework for future conferences and courses. The solid partnership between the task force principals and the EEO staff promotes open and regular communication that continues to result in high quality, well-received training. Specific accomplishments dur- ing 2010 for the EEO were two well received pilots of the Struc- tured Finance and Distressed Commercial Real Estate courses. These courses have been added to the 2011 training calendar with a combined total of 15 sessions. Additionally, updates to the BSA/ AML Examination Manual and the Information Technology Exami- Calvin Moye instructs students at the FFIEC's Real Estate Appraisal Review School II.

9 FFIEC agencies in support of referred, with recommendations, to gram to share, in accordance with the supervision, regulation, and the Council for action, and the task agency policy, electronic versions deposit insurance responsibilities force has delegated authority from of their reports of examination, of financial institution regulators. the Council to take certain actions. inspection reports, and other com- The task force provides a forum for munications with financial institu- FFIEC member agencies to discuss To the extent possible, the agencies tions. The agencies also provide and address issues affecting the build on each other’s information each other with access to their quality, consistency, efficiency, and databases to minimize duplication organizations’ structure, financial, security of interagency information of effort and promote consistency. and supervisory information on sharing. Significant matters are The agencies participate in a pro- their regulated entities. The task

2010 FFIEC Training by Agency and Sponsored—Actual, as of December 31, 2010

FRB FDIC State State Event Name FRB Sponsored FDIC Sponsored NCUA OCC OTS FCA FHFB Other Total

Advanced BSA/AML Conference 1 11 61 13 7 22 16 0 0 5 136 Advanced Cash Flow Concepts & Analysis: Beyond 20 13 35 0 2 28 9 5 0 0 112 Advanced Commercial Credit Analysis 17 9 71 24 6 21 8 0 2 0 158 Anti-Money Laundering Workshop 4 19 39 17 9 0 21 0 0 8 117 Advanced Fraud Investigation Techniques for Examiners 0 6 17 3 8 6 1 1 1 0 43

Asset Management Forum 0 14 62 19 1 21 7 0 0 0 124 Capital Markets Conference 16 21 68 8 7 21 19 1 2 0 163 Capital Markets Specialists Conference 13 7 80 4 9 14 17 19 9 0 172 Cash Flow Construction and Analysis 21 11 26 11 11 28 8 2 0 0 118 Commercial Real Estate 34 8 146 25 35 48 37 0 3 1 337

Community Financial Institutions Lending Forum 9 9 39 9 3 12 6 7 0 0 94 Distressed Commercial Real Estate Analysis Pilot I 1 0 2 0 2 4 2 0 0 3 14 Financial Crimes Seminar 9 20 72 13 13 0 27 2 0 11 167 Fraud Identification On-line Training 1 0 5 0 4 6 4 1 0 1 22 Information Technology Symposium 3 0 3 0 3 4 4 0 0 1 18

Fundamentals of Fraud 0 0 6 10 3 11 7 1 0 5 43 Information Technology Conference 11 11 36 18 7 32 38 14 3 0 170 Instructor Training School 7 3 2 0 1 7 0 6 0 4 30 International Banking School 3 4 5 4 0 3 0 0 0 1 20 International Banking (Self-Study) 10 0 3 0 0 11 2 0 0 6 32

Payment Systems Risk Conference 11 6 20 5 3 20 7 0 1 11 84 Real Estate Appraisal Review School II 20 13 47 0 4 0 2 4 0 0 90 Real Estate Appraisal Review I (On-line) 2 0 8 0 2 0 0 0 0 0 12 Supervisory Updates & Emerging Issues 44 15 66 20 9 42 27 10 7 0 240 Structured Finance Pilot II 4 0 3 0 2 3 4 0 0 4 20 Testifying School 0 0 17 0 0 9 0 0 0 0 26

Grand Total 261 200 939 203 151 373 273 73 28 61 2,562 Percentage 10.19 7.81 36.65 7.92 5.89 14.56 10.66 2.85 1.09 2.38 100

Combined Agency and Sponsored Percentage 17.99 NA 44.57 NA 5.89 14.56 10.66 2.85 1.09 2.38 100

10 force and its working groups use a collaborative website to share information among the FFIEC agencies. The task force maintains a “Data Exchange Summary” list- ing the data files exchanged among FFIEC agencies and a repository of communications and documents critical to information sharing. The task force has established three working groups to address technology-development issues, to perform interagency reconciliation of financial institution structure data, and to develop interagency identity management. In addi- tion, the task force receives dem- onstrations and reports on agency, financial industry, and other FFIEC initiatives pertaining to technol- Task Force on Information Sharing's Technology Working Group meeting. ogy development; including the production and development sta- tus of the interagency Central Data ical materials pertaining to inter- cies to ensure that the information Repository. agency information exchanges are the agencies report is consistent stored. TWG efforts addressed in and accurate. The SDRWG’s quar- 2010 include: terly reconcilements have greatly resolved structure data discrepan- Initiatives Addressed in 2010 • SNC Modernization—All agen- cies among the agencies. cies completely implemented Technology Issues new Shared National Credit schemas and are processing Identity Management The mission of the task force is to XML files. identify and implement technolo- In 2010, the Identity Management gies to make the sharing of inter- • NIC 2.0—Agencies began pre- Working Group prepared a white agency data more efficient and to paring to accommodate the NIC paper illustrating the benefits of accommodate changes in agency 2.0 data feed in preparation for piloting an Identity Management databases and technologies. The NIC 2.0 becoming the system technology framework within the task force’s Technology Working of record by the end of March FFIEC agencies. A presentation Group (TWG) meets monthly to 2011. was made late in the year to the develop technological solutions to agencies’ Chief Information Offi- enhance data sharing and to coor- • Interagency Data Exchange cers at one of their periodic meet- dinate the automated transfer of (IADE) Project Plan Update— ings in order to gain their support data files between the FFIEC agen- Agencies fully completed the for moving forward. The purpose cies. The group is heavily involved effort to migrate data series of the document was to brief them with weekly tracking of the inter- from mainframe BulkData on the new information challenges agency exchanges given the recent transfer to Connect:Direct/XML presented by the recent financial transition to using XML, delta files, processes. BulkData is now reforms, and to achieve a consen- and Connect: Direct. retired. sus on the scope and urgency of the efforts needed to meet these The TWG continues to develop Structure Data Reconciliation challenges going forward. necessary links and processes to exchange electronic documents, The task force’s Structure Data develop an inventory of future Reconciliation Working Group Task Force on Reports technology projects, and upload (SDRWG) continued to reconcile information to the collaborative structure data about financial insti- The law establishing the Council website where documents and crit- tutions regulated by FFIEC agen- and defining its functions requires

11 the Council to develop uniform reporting systems for federally supervised financial institutions and their holding companies and subsidiaries. To meet this objec- tive, the Council established the Task Force on Reports. The task force helps to develop inter- agency uniformity in the report- ing of periodic information that is needed for effective supervision and other public policy purposes. As a consequence, the task force is concerned with issues such as the development and interpretation of reporting instructions; including responding to inquiries about the instructions from reporting insti- tutions and the public, the appli- cation of accounting standards to specific transactions, the develop- ment and application of process- ing standards, the monitoring of data quality, and the assessment Task Force on Reports meeting. of reporting burden. In addition, the task force works with other Reports of Condition and Income in 2010. The revisions responded organizations, including the Secu- () filed by insured to such developments as a tempo- rities and Exchange Commis- commercial banks and state- rary increase in the deposit insur- sion, the Financial Accounting chartered savings banks. The CDR ance limit, changes in accounting Standards Board (FASB), and the also processes and distributes the standards, and credit availability American Institute of Certified Uniform Bank Performance Report concerns. The reporting changes Public Accountants. The task (UBPR) under the oversight of that took effect March 31, 2010, force is also responsible for any the Task Force on Surveillance included new data on loans to special projects related to these Systems. non-depository institutions and subjects that the Council may on other-than-temporary impair- assign. ment of debt securities, additional Initiatives Addressed in 2010 data on certain time deposits To help the task force carry out its and unused commitments, and Reporting Requirements for the responsibilities, working groups a change from annual to quar- Consolidated Reports of Condition are organized as needed to handle terly reporting for small business and Income specialized or technical account- and small farm lending data and ing, reporting, instructional, and After receiving approval under the for the number of certain deposit processing matters. In this regard, Paperwork Reduction Act (PRA) accounts. Annual collection of new the task force has established a from the U.S. Office of Manage- data pertaining to reverse mort- Central Data Repository (CDR) ment and Budget (OMB) in March gages began December 31, 2010. Steering Committee to make busi- 2010, the Federal Deposit Insur- The Office of Thrift Supervision ness decisions needed to ensure ance Corporation (FDIC), the (OTS) implemented several of the success of the CDR initiative, Board of Governors of the Federal the same reporting changes in monitor the project status, and Reserve System (Federal Reserve the Thrift Financial Report report on its progress. The CDR is Board or FRB), and the Office of (TFR) filed by savings associations. a secure shared database for col- the Comptroller of the Currency lecting, managing, validating, (OCC) (collectively, the bank- During the second and third quar- and distributing data reported ing agencies) implemented sev- ters of 2010, the task force evalu- in the quarterly Consolidated eral revisions to the Call Report ated recommendations from the

12 banking agencies and a bank- enable the agencies to modify the associations. Common reporting ers’ association for potential Call UBPR’s definitions related to core would lead to more uniform com- Report revisions to be imple- deposits and non-core liabilities. parisons of financial condition, mented in March 2011. After con- Following task force approval, the performance, and trends among sidering the purposes for which banking agencies jointly published institutions. For these reasons, the banking agencies would use a final PRA Federal Register notice the OTS decided to propose the the recommended new or revised for the March 2011 Call Report elimination of the TFR, and the data and the reasons for certain revisions in January 2011. OMB agencies agreed to propose requir- proposed instructional clarifica- must approve these revisions ing savings associations to begin tions and modifications, the task before they become final. filing the Call Report effective force approved the inclusion of March 31, 2012. Following task In June 2009, the FASB established several of the recommendations in force approval of an initial PRA the Accounting Standards Codi- a proposal to be issued for com- Federal Register notice for the pro- fication as the single source of ment. The proposed revisions posed migration of savings asso- authoritative nongovernmental were intended to assist the bank- ciations from the TFR to the Call U.S. generally accepted account- ing agencies in gaining a better Report, the agencies jointly pub- ing principles. The FASB Codi- understanding of banks’ credit and lished this notice for comment in fication reorganized all existing liquidity risk exposures; primarily February 2011. At the same time, U.S. accounting and reporting through enhanced data on lending the FRB published a notice of its standards from a standards-based and securitization activities and intent to require savings and loan model to a topically-based model. sources of deposits. In September holding companies to submit to During the second quarter of 2010, 2010, the banking agencies pub- the FRB all regulatory reports cur- the task force began incorporating lished an initial PRA Federal Regis- rently required to be filed by bank FASB Codification references into ter notice requesting comment for holding companies beginning in the Call Report instruction book. 60 days on the proposed March the first quarter of 2012. In addi- In the instruction book update 2011 reporting and instructional tion, the OTS and the FDIC jointly for September 30, 2010, the FFIEC changes. The OTS incorporated published an initial PRA Federal issued a revised glossary section some of the proposed Call Report Register notice proposing the elimi- of the book that adds Codifica- changes into a separate set of pro- nation of the OTS’s annual Branch tion references throughout while posed revisions to the TFR for Office Survey and the submis- retaining references to the pre- which an initial PRA Federal Regis- sion by savings associations of the Codification standards. The task ter notice was published in Octo- FDIC’s similar annual Summary of force expects to incorporate Codi- ber 2010. Deposits Survey effective June 30, fication references into the rest of 2011. Finally, the OTS published the Call Report instruction book After considering the 23 com- a notice of its intent to cease col- in 2011. ments received on the March 2011 lection of monthly median cost of Call Report proposal, the banking The Dodd-Frank Wall Street funds data from savings associa- agencies agreed to proceed with Reform and Consumer Protection tions effective January 31, 2012. most, but not all, of the reporting Act (the Dodd-Frank Act) abol- Savings associations and their changes that had been proposed. ishes the OTS and transfers its holding companies would con- Modifications were made to functions to the OCC, the FDIC, tinue their current reporting pro- some of the proposed changes in and the FRB effective July 21, cesses through the effective dates response to comments. In addition, 2011, or the designated date pub- specified above. the agencies received comments lished in the Federal Register by the that discussed the permanent Department of Treasury Secretary. In November 2009, the task force increase in the deposit insurance After careful review, the bank- initiated a project to combine the limit to $250,000 that was enacted ing agencies and the OTS (collec- two Call Report forms into one in July 2010 and its implications tively, the agencies) concluded that form. A single form would reduce for the calculation of core deposits having common financial reports redundancies when the bank- in the UBPR. The banking agen- and reporting processes among ing agencies implement meta- cies concluded that these com- all FDIC-insured banks and sav- data changes in the CDR system ments would support revisions to ings institutions would be more whenever the Call Report forms or two existing Call Report deposit efficient than maintaining the instructions are revised. Combin- items in March 2011, which would OTS’s separate reports for savings ing the two Call Report forms into

13 a single form is not intended to to improve Call Report process- than $250,000 beginning Decem- increase the amount of data that ing, public data distribution, and ber 31, 2010. Following task force any bank is currently required UBPR processing. approvals, the banking agencies to report each quarter. In June and the OTS jointly published 2010, the task force shared a draft Other Activities initial and final PRA Federal combined form with the banking Register notices requesting agencies’ Call Report data users In April 2010, the FDIC Board comment on the proposed and analysts, and solicited their extended the Transaction Account collection of this information input on implementation issues Guarantee (TAG) Program from in the Call Report, the TFR, and that may arise from the introduc- June 30 to December 31, 2010. the FFIEC 002 report in Septem- tion of a single form. Feedback on The FDIC Board also changed the ber and November 2010, respec- the implications of this change for basis for calculating assessments tively. OMB approved this downstream agency systems and beginning in the third quarter of reporting change in December UBPR ratios led the task force to 2010 from quarter-end to daily 2010. defer combining the two forms average balances. This necessi- into one form to a date beyond tated a change in the TAG Pro- In August 2010, the task force March 2011. The task force’s gram assessment data collected in approved, and the FRB pub- options for moving forward on the Call Report, the TFR, and the lished on behalf of the banking this project are also affected by Report of Assets and Liabilities agencies, an initial PRA Federal the proposed migration of savings of U.S. Branches and Agencies of Register notice requesting com- associations from the TFR to the Foreign Banks (FFIEC 002 report) ment on proposed revisions to the Call Report in March 2012. from those FDIC-insured institu- FFIEC 002 report that would take tions electing to participate in the effect in March 2011. These revi- The task force conducted monthly program extension. Following sions incorporate several recent interagency conference calls dur- task force approvals, the bank- bank Call Report revisions into ing 2010 to discuss Call Report ing agencies and the OTS jointly the FFIEC 002 report: additional instructional matters and related published initial and final PRA detail on trading assets, changes accounting issues to reach uni- Federal Register notices requesting to the reporting of certain time form interagency positions on comment on the proposed basis deposits, and additional detail these issues. of reporting TAG Program data and modified criteria for report- in these three reports in May and ing on assets and liabilities mea- Central Data Repository August 2010, respectively. OMB sured at fair value. One comment approved this reporting change in was received supporting the pro- During 2010, the agencies con- September 2010. posed revisions. Following task tinued to devote significant staff force approval, the FRB published resources to enhance the CDR for Section 343 of the Dodd-Frank a final PRA Federal Register notice processing the quarterly bank Call Act amended the Federal Deposit in January 2011. OMB approval of Reports and the UBPR. Insurance Act to provide tem- the FFIEC 002 reporting changes The agencies’ work during the porary unlimited insurance cov- is pending. first quarter was dedicated pri- erage to noninterest-bearing marily to the tasks associated transaction accounts at all FDIC- In September 2010, an interagency with completing the implementa- insured institutions. This insur- group of subject matter experts tion of the UBPR within the CDR. ance coverage is in effect from on Basel II data collection recom- The CDR became the system of December 31, 2010, through mended a limited number of revi- record for the UBPR on March 29, December 31, 2012, and replaces sions to the Advanced Capital 2010. In conjunction with the Task the FDIC's TAG Program. To Adequacy Framework Regulatory Force on Surveillance Systems, support its administration of Reporting Requirements (FFIEC the banking agencies now process the Deposit Insurance Fund in 101 report). These changes to the and distribute the UBPR using response to Section 343, the FDIC report, which would be imple- the interagency CDR Public Data determined that each insured mented in March 2011, would Distribution website. In addi- institution should report the merge the separate banking orga- tion, the agencies implemented a quarter-end dollar amount and nization and savings association major CDR enhancement release number of noninterest-bearing schedules for calculating total in December 2010. The December transaction accounts (as defined capital, segregate the report- release provided enhancements in the Dodd-Frank Act) of more ing by bank holding companies

14 of certain restricted core capital elements from other core capi- tal elements, and streamline the reporting of equity exposures. In October 2010, the task force approved and the agencies pub- lished an initial PRA Federal Reg- ister notice requesting comment on these proposed revisions and an extension for three years of the agencies’ authority to collect the FFIEC 101 report. No comments were received on the proposal. Following task force approval, the agencies published a final PRA Federal Register notice for the FFIEC 101 report in Janu- ary 2011. Approval by OMB is pending.

Task Force on Supervision meeting. Task Force on Supervision The Task Force on Supervision • The Capital Subcommittee serves ledger systems, and other criti- coordinates and oversees matters as a forum for senior policy cal software tools that are used relating to safety-and-soundness staff members to discuss vari- by a large number of financial supervision and examination of ous initiatives pertaining to institutions. These programs depository institutions. It pro- the agencies’ regulatory capital help the agencies identify vides a forum for the member standards. potential systemic risks and agencies and State Liaison Com- provide examiners with infor- mittee to promote quality, con- • The Information Technology (IT) mation that can reduce time sistency, and effectiveness in Subcommittee serves as a forum and resources needed to exam- examination and supervisory to address information systems ine the IT-related processing practices. While significant issues and technology policy issues software and external services are referred, with recommenda- as they relate to financial insti- at user financial institutions. tions, to the Council for action, tutions. The IT Subcommittee the Council has delegated to the oversees and administers the • The Bank Secrecy Act/Anti- task force the authority to make FFIEC member agencies’ Tech- Money Laundering (BSA/ certain decisions and recom- nology Service Provider (TSP) AML) Working Group seeks mendations, provided all task Examination and Shared Appli- to enhance coordination of force members agree. Meetings cation Software Review (SASR) BSA/AML training, guidance, are held regularly to address programs. Through the FFIEC’S and policy. The coordination and resolve common supervi- Multi-Regional Data Processing includes continuing commu- sory issues. The task force has Servicer program, the agencies nication between federal and also established and maintains conduct joint information tech- state banking agencies and supervisory communication pro- nology examinations of the larg- the Financial Crimes Enforce- tocols to be used in emergencies. est, systemically important tech- ment Network. The BSA/ These protocols are periodically nology service providers and AML Working Group builds tested through table-top exercises other entities that provide criti- on existing efforts and works with task force members and key cal banking services. The SASR to strengthen the activities supervisory personnel. program provides a mechanism that are already being pursued for the agencies to review and by other formal and informal The task force has two subcom- share information on mission- interagency groups providing mittees and a standing working critical software applications, oversight of various BSA/ group: such as loans, deposits, general AML matters. BSA/AML

15 training, guidance, and policy nomic conditions present signifi- and bargain purchase transac- includes: (1) procedures and cant risk management challenges tions, as well as certain account- resource materials for examina- to institutions of all sizes. In this ing and regulatory report- tion purposes; (2) joint exam- challenging environment, the task ing requirements for business iner training related to the force established working groups combinations. FFIEC’s BSA/AML Examina- to prepare the following issuances, tion Manual; (3) outreach to the which serve to reaffirm supervi- • On April 30, 2010 the OCC, banking industry on BSA/AML sory expectations for sound risk OTS, FRB, and FDIC issued policy matters; and (4) other management practices by federal final guidance to address the issues related to consistency of financial institutions: concentration risk attendant to BSA/AML supervision. correspondent banking relation- • On January 7, 2010, the FFIEC ships by managing the credit The task force also establishes ad released an advisory, adopted and funding risk associated hoc working groups to handle by the agencies, on sound inter- with large exposures to corre- individual projects and assign- est rate risk (IRR) management spondent counterparties. ments, as needed. practices for depository insti- tutions. The advisory empha- • On December 2, 2010, inter- sizes the importance of effective agency appraisal and evalua- Initiatives Addressed in 2010 corporate governance, policies tion guidelines were issued that update and clarify the agencies’ SAFE Act and procedures, risk measuring and monitoring systems, stress minimum regulatory standards A task force working group, testing, and internal controls for appraisals. The guidelines together with the Farm Credit related to the IRR exposures of emphasize that financial institu- Administration (FCA), contin- institutions. It also clarifies vari- tions are responsible for select- ued to coordinate efforts among ous elements of existing guid- ing appraisers and people per- the FFIEC agencies to imple- ance and describes selected IRR forming evaluations based on ment provisions of the Secure and management techniques used their competence, experience, Fair Enforcement for Mortgage by effective risk managers. and knowledge of the mar- Licensing Act of 2008 (the Act). ket and type of property being As required by the Act, mort- • On March 17, 2010 the FFIEC valued. The guidelines also gage loan originators (MLOs) member agencies, in conjunc- address advancements in infor- employed by institutions that are tion with Conference of State mation technology used in col- regulated by a federal banking Bank Supervisors (CSBS) pub- lateral valuation practices, and agency or the FCA must register lished final guidance on sound clarify standards for the indus- with the Nationwide Mortgage funding and liquidity risk man- try’s appropriate use of analyti- Licensing System and Registry agement practices. The guid- cal methods and technological (NMLSR), obtain a unique identi- ance summarizes the principles tools in developing evaluations. fier and maintain this registration. of sound liquidity risk manage- As envisioned, the NMLSR will ment issued previously by the Information Technology agencies and, when appropri- improve the flow of information Financial institutions’ significant to and between regulators, provid- ate, supplements them with the “Principles for Sound Liquidity use of information technology ser- ing increased accountability and vices, whether generated inter- tracking of MLOs, enhancing con- Risk Management and Super- vision” issued in September nally or obtained from third-party sumer protections, and providing service providers, contributes to consumer access to certain infor- 2008 by the Basel Committee on Banking Supervision. their operational risk environ- mation on MLOs. In July 2010, ment in general and their data the FFIEC agencies and the FCA • On June 7, 2010, an interagency security risk in particular. A major issued the final rule to implement policy statement on business effort of the Information Technol- the requirements of the SAFE Act, combinations and FDIC- and ogy Subcommittee (Subcommit- with an effective date of October NCUA-assisted transactions tee) and agencies is maintaining 1, 2010. was issued that addresses the the FFIEC Information Technol- agencies’ supervisory expecta- Enhanced Risk Management ogy Examination Handbook. The tions and licensing consider- Practices handbook consists of a series of ations for financial institutions topical booklets addressing issues Current financial market and eco- engaged in assisted acquisitions such as business continuity plan-

16 ning, information security, and Shared Application Software Systems oversees the develop- electronic banking. In 2010, the Review (SASR) Program designed ment and implementation of uni- FFIEC published an update of the to provide a uniform report on form interagency surveillance and Retail Payment Systems Booklet. widely used software applica- monitoring systems. It provides a The booklet provides guidance to tions to the agencies and non- forum for the member agencies to examiners, institutions, and tech- information technology examiners discuss best practices to be used nology service providers on identi- who examine banks using these in those systems and to consider fying and controlling risks associ- software applications. The uni- the development of new finan- ated with retail payment systems form report was revised in 2009 cial analysis tools. The task force’s and related activities. During the to enhance the efficiency of the principal objective has been to year, the Subcommittee devoted review process for the original develop and produce the Uniform resources to enhancing the FFIEC’s SASR program approved by the Bank Performance Report (UBPR). InfoBase so that updates to sec- task force in 1990. UBPRs present financial data and tions that are common to more peer group statistics of individual than one handbook could be more Capital Standards banks for current and historical efficiently updated. Although each of the four fed- periods. These reports are impor- tant tools for completing supervi- The Subcommittee, in conjunction eral banking agencies has its sory evaluations of a bank’s condi- with the Task Force on Examiner own capital regulations, the task tion and performance, as well as Education, sponsors an annual force’s standing Capital Subcom- for planning onsite examinations. Information Technology confer- mittee and several of its working The banking agencies also use ence for the agencies’ examination groups promote joint issuance of the data from these reports in staff on emerging risks and indus- capital rules and related interpre- their automated monitoring sys- try best practices. The Subcom- tive guidance, thereby minimiz- tems to identify potential or mittee is also responsible for the ing interagency differences and emerging problems in insured coordination of the Multiregional reducing the potential burden on banks. Data Processing Servicer (MDPS) the banking industry. The federal Program Oversight, which is banking agencies have been re- A UBPR is produced for each com- ongoing. The FFIEC member agen- examining our capital adequacy mercial bank and insured savings cies examine MDPS organizations framework in light of the recent bank in the United States that is because these entities pose a sys- financial stress. supervised by the Federal Reserve temic risk to the banking system Board, the Federal Deposit Insur- should one or more have opera- BSA/AML Working Group ance Corporation, or the Office of tional or financial problems or The BSA/AML Working Group the Comptroller of the Currency. fail. Since these companies service completed revisions to the BSA/ UBPR data are also available to banks, thrifts, and credit unions, AML Examination Manual (Man- all state bank supervisors. While the FFIEC member agencies con- ual) and examination procedures. the UBPR is principally designed duct interagency examinations The agencies released the Manual to meet the examination and sur- of these large technology service on April 29, 2010. veillance needs of the federal providers. Interagency examina- and state banking agencies, the tions provide a single examination The BSA/AML working group task force also makes the UBPR report for the service providers. sponsored its fourth FFIEC available to banks and the public In February 2010 the Subcommit- Advanced BSA/AML Specialists through a public website, www. tee held a supervisory strategy Conference in July 2010. Feedback ffiec.gov/UBPR.htm. meeting with interagency exami- from the conference was positive. nation teams from each MDPS to The agencies continued to share approve the examination strategies information with the Financial Initiatives Addressed in 2010 and schedules. The meeting also Crimes Enforcement Network and included a roundtable discussion with the Office of Foreign Assets Enhanced the Delivery of among ITS principals and senior Control. UBPR Data management from some of the The task force approved conver- MDPS companies. Task Force on sion of UBPR data processing and The FFIEC member agencies com- Surveillance Systems delivery to a completely new sys- pleted examiner training via a tem in the FFIEC Central Data webinar in March 2010 on the The Task Force on Surveillance Repository (CDR). The multi-year

17 ule RC-L beginning March 31, 2010.

Improved UBPR Analysis of Loans Ratios that analyze loan mix and concentrations found on UBPR Page 7A Analysis of Credit Allow- ance and Loan Mix and UBPR Page 7B Analysis of Concentra- tions of Credit were revised to uti- lize new information reported on loans to non-depository financial institutions and other loans on Call Report Schedule RC-C beginning March 31, 2010.

UBPR Delivered to a Wide Audience UBPR for December 31, 2009; March 31, 2010; June 30, 2010; and September 30, 2010 were produced Task Force on Surveillance Systems meeting. and delivered during 2010 to fed- eral and state banking agencies. Additionally, the UBPR website project included extensive analy- • Expanded state-based peer was utilized to deliver the same sis and testing during 2010 before group analysis data to bankers and the general approval as the system of record public. The task force strives to deliver the most up-to-date UBPR for UBPR data. Bankers, bank Improved UBPR Analysis of Deposits supervisors, and the general data to all users. Thus current and public have available many Ratios that analyze brokered historic UBPR data is updated improvements to the UBPR deposits as well as core and non- nightly. Frequent updating allows including: core deposits were revised to uti- the UBPR to remain synchronized lize new detail reported in the with new Call Report data as it is • Nightly updating of UBPR data March 31, 2010 Call Report Sched- being submitted by banks. ule RE-E. New data reported • Next day availability of UBPR included information on brokered report when a Call Report is deposits and large time deposits. filed Projects Planned for 2011 Ratios found on the UBPR Page 4 Balance Sheet $, UBPR Page 6 Bal- • Liquidity and funding—The task • View, print, and download all force approved a working group reports ance Sheet %, and UBPR Page 10 Liquidity and Investment Portfolio to review UBPR treatment of • Custom Peer Group Tool can were affected. liquidity measures, core and deliver a re-computed report in non-core funding and overall seconds funding analysis. The review Improved UBPR Analysis of will include all Call Report • Download all UBPR data in Off-balance Sheet Activities changes planned for 2011. delimited files at no charge Ratios that analyze off-balance • Fiduciary activities—The task • Standardized format for all sheet activities found on UBPR force approved a working group reports Page 5 Off Balance Sheet Items to review the UBPR treatment were revised to utilize new of fiduciary data obtained from • Retention of all quarterly information on commitments on Call Schedule RC-T. This will be UBPR data beginning Decem- 1–4 family mortgages and other the first comprehensive review ber 2001 loans found in Call Report Sched- of this information since imple-

18 mentation in 2002 and will try and public access to informa- on financial and geographical cri- encompass new data collected tion about the financial condi- teria. The tool can then display in the 2009 Call Report. tion of insured banks, the task all UBPR pages with peer group force publishes UBPR data for statistics and percentile rankings • Improved documentation of UBPR each institution shortly after the derived from the custom peer ratios—The task force is under- underlying Call Report is filed in group. The Custom Peer Group taking a complete rewrite of the CDR. The UBPR is frequently Tool can re-compute the entire the UBPR Users Guide. The refreshed to reflect amendments UBPR using a custom peer group review will re-focus the guide to underlying Call Report data of up to 2,000 banks and deliver as a technical reference manual and to incorporate any content- the results usually within seconds. to provide Call Report based based changes agreed to by the explanations of UBPR ratios. task force. The on-line UBPR is The guide will also offer high Bulk Data Download a dynamic report that is closely level explanations and define synchronized with the underlying The UBPR database within the peer groups, peer group com- Call Report. CDR containing all data appear- putations, and related elements ing on report pages for all banks as well. may be downloaded as either a Other UBPR Reports • Government guaranteed loans— delimited file or in XBRL format. The task force will implement Several web-based statistical There is no charge for this service new ratios on UBPR Page 8 reports supporting UBPR analysis and downloads are typically fast. Analysis of Past Due, Nonac- are also available and are updated Please visit www.ffiec.gov/UBPR. crual & Restructured and UBPR nightly on the website. These htm for additional information Page 8A Analysis of Past Due, reports (1) summarize the perfor- about the UBPR, including status, Nonaccrual & Restructured mance of all UBPR peer groups descriptions of pending changes, that will analyze the impact of (determined by size, location, and and the UBPR Users Guide. The government guarantees on past business line), (2) detail the dis- site also provides access to the due loans. Along with ratios tribution of UBPR performance reports described above. For ques- the UBPR will display associ- ratios for banks in each of these tions about the UBPR contact sup- ated peer group averages and peer groups, (3) list the individ- port by calling 1-888-237-3111, percentile rankings. The data ual banks included in each peer emailing [email protected], or will be calculated for all his- group, and (4) compare a bank to writing the Council at: toric quarters in the CDR. the performance of a user-defined custom peer group. Federal Financial Institutions Examination Council Custom Peer Group Tool 3501 Fairfax Drive, Room B7081a Information Available on the Arlington, VA 22226-3550 UBPR Website The Custom Peer Group Tool UBPR Availability allows bankers, bank supervi- sors, and the general public to To provide broad banking indus- create custom peer groups based

19

THE FEDERAL FINANCIAL INSTITUTION REGULATORY AGENCIES AND THEIR SUPERVISED INSTITUTIONS

The five federal financial insti- for insurance with the Federal tution regulatory agencies rep- Deposit Insurance Corpora- resented on the Council have tion. According to the Federal primary federal supervisory juris- Deposit Insurance Corporation diction over 15,218 domestically Improvement Act of 1991 (FDI- chartered banks, thrift institutions, CIA), foreign banks that wish to and credit unions. On December operate insured entities in the 31, 2010, these financial institu- United States and accept retail tions held total assets of more than deposits must organize under $16.1trillion. The Board of Gover- separate U.S. charters. Exist- nors of the Federal Reserve System ing insured retail branches may and the Office of Thrift Supervision continue to operate as branches. also have primary federal supervi- The IBA also subjects those sory responsibility for commercial U.S. offices of foreign banks to bank holding companies and for many provisions of the Fed- savings and loan holding compa- eral Reserve Act and the Bank nies, respectively. Holding Company Act. The IBA gives primary examining Three banking agencies on the authority to the Office of the Council have authority to over- Comptroller of the Currency, see the operations of U.S. branches the Federal Deposit Insurance and agencies of foreign banks. Corporation, and various state The International Banking Act of authorities for the offices within 1978 (IBA) authorizes the Office their jurisdictions. The IBA also of the Comptroller of the Cur- gives the Board of Governors rency to license federal branches of the Federal Reserve System and agencies of foreign banks and residual examining authority permits U.S. branches that accept over all U.S. banking operations only wholesale deposits to apply of foreign banks.

21 Board of Governors of the the United States, as well as the Federal Reserve System domestic activities of foreign banking organizations; The Federal Reserve Board was established in 1913. It is headed by • developing, issuing, imple- a seven-member Board of Gover- menting, and communicating nors; each member is appointed regulations, supervisory poli- by the President, with the advice cies and guidance, and tak- and consent of the Senate, for a ing appropriate enforcement fourteen-year term. Subject to con- actions applicable to those firmation by the Senate, the Presi- organizations that are within dent selects one Board member to the Federal Reserve Board’s serve a four-year term as Chair- supervisory oversight author- person and two members to serve ity; and as Vice Chairs; one serves in the • approving or denying appli- absence of the Chairperson and cations for mergers, acquisi- the other is designated as Vice tions, and changes in control Chair for Supervision. The Federal by state member banks and Reserve Board’s activities most rel- BHCs (including FHCs), appli- evant to the work of the Council cations for foreign operations are the following: of member banks and Edge Act • overseeing the quality and effi- and agreement corporations, ciency of Reserve Bank exami- and applications by foreign nations and supervision; moni- banks to establish or acquire toring of the financial condition, U.S. banks and to establish U.S. operations, and systemic risk of branches, agencies, or represen- state member banks (i.e. state- tative offices. chartered banks that are mem- Other supervisory and regula- bers of the Federal Reserve Sys- tory responsibilities of the Federal tem), bank holding companies Reserve Board include regulating (BHCs) (including financial margin requirements on securities 1 holding companies (FHCs)), transactions, implementing cer- Edge Act and agreement cor- tain statutes that protect consum- porations, and, in conjunction ers in credit and deposit transac- with the licensing authorities, tions, monitoring compliance with carrying its authority to super- other statutes (e.g. the money- vise and regulate the interna- laundering provisions of the Bank tional operations of banking Secrecy Act), and regulating trans- organizations headquartered in actions between banking affiliates. Policy decisions are implemented 1. The Federal Reserve Board’s role as the by the Federal Reserve Board or supervisor of a BHC or FHC is to review under delegated authority to the and assess the consolidated organiza- tion’s operations, risk-management sys- Director for the Division of Bank- tems, and capital adequacy to ensure ing Supervision and Regulation that the holding company and its non- and to the twelve Federal Reserve bank subsidiaries do not threaten the Banks—each of which has oper- viability of the company’s depository ational responsibility within a institutions. In this role, the Federal Reserve Board serves as the “umbrella specific geographical area. The supervisor” of the consolidated organi- Reserve Bank Districts are head- zation. In fulfilling this role, the Federal quartered in Boston, New York, Reserve Board relies to the fullest extent Philadelphia, Cleveland, Rich- possible on information and analysis provided by the appropriate supervi- mond, Atlanta, Chicago, St. Louis, sory authority of the company’s bank, Minneapolis, Kansas City, Dallas, securities, or insurance subsidiaries. and San Francisco. Each Reserve

22 Bank has a president (chief execu- ity for foreign banking operations, 4. Development of enhanced tive officer) who serves for 5 years including both U.S. banks operat- prudential standards for large and is appointed by the bank’s ing abroad and foreign banks oper- BHCs with $50 billion or more class B and class C directors, and ating branches within the United in assets, and systemically sig- other executive officers who report States. nificant FSOC-designated non- directly to the president. Among bank financial firms (including other responsibilities, a Reserve On July 21, 2010, the President requirements relating to capital, Bank employs a staff of examin- signed the financial regulatory liquidity, stress tests, risk man- ers —who examine state member reform bill (the Dodd-Frank Wall agement, concentration limits, banks and Edge Act and agree- Street Reform and Consumer Pro- and credit exposure reporting). 2 ment corporations, conduct BHC tection Act (the Dodd-Frank Act)). The Dodd-Frank Act gives the Fed- Additionally, the Dodd-Frank inspections, and examine the eral Reserve Board new responsi- Act created an independent international operations of foreign bilities including: Consumer Financial Protection banks—whose head offices are Bureau, housed within the Fed- usually located within the Reserve 1. Membership in the newly eral Reserve Board, and charged Bank’s District. When appropri- formed Financial Stability Over- with administering the consumer ate, examiners also visit the over- sight Council (FSOC). The financial protection laws. seas offices of U.S. banking orga- FSOC’s responsibilities include nizations to obtain financial and identifying risks to financial The Federal Reserve Board cov- operating information to evaluate stability and promoting market ers the expenses of its operations adherence to safe and sound bank- discipline. The FSOC has 10 des- with revenue it generates prin- ing practices. ignated voting members and cipally from assessments on the 5 designated nonvoting advi- twelve Federal Reserve Banks. National banks, which must be sory members. The Dodd-Frank Act directs the members of the Federal Reserve Federal Reserve Board to col- System, are chartered, regulated, 2. Supervision of nonbank finan- lect assessments, fees, and other and supervised by the Office of cial firms that are designated as charges that are equal to the the Comptroller of the Currency. systemically important by the expenses incurred by the Federal State-chartered banks may apply FSOC. Reserve to carry out its responsi- to and be accepted for member- bilities with respect to: (1) BHCs ship in the Federal Reserve Sys- 3. Supervision and regulation of and SLHCs with assets equal to tem, after which they are subject to savings and loan holding com- or greater than $50 billion; and (2) the supervision and regulation of panies (SLHCs). all non-bank financial companies the Federal Reserve Board, which supervised by the Federal Reserve is coordinated with the state’s 2. Public Law No. 111-203, 124 Stat. 1376 (2010). Most provisions of the Dodd- Board.3 banking authority. Insured state- Frank Act have general effective dates chartered banks that are not mem- that are either effective on (1) the “trans- bers of the Federal Reserve Sys- fer date” of the Office of Thrift Super- 3. The effective date is one-year after the date of the Dodd-Frank Act’s tem are regulated and supervised vision, which is one-year after the date of enactment (July 21, 2011), or (2) one enactment. by the Federal Deposit Insurance day after the date of enactment (July Corporation. The Federal Reserve 22, 2010), unless otherwise specifically Board also has overall responsibil- stated in the Act.

23 Federal Deposit Insurance On November 9, 2010, the FDIC Corporation Board of Directors issued a final rule to implement Section 343 Congress created the Federal of the Dodd-Frank Act to Deposit Insurance Corporation provide temporary unlimited (FDIC) in 1933 with a mission to deposit insurance coverage for insure bank deposits and reduce noninterest-bearing transac- the economic disruptions caused tion accounts at all FDIC-insured by bank failures. Management depository institutions. The sepa- of the FDIC is vested in a five- rate coverage for noninterest- member Board of Directors. No bearing transaction accounts more than three board members became effective on December 31, may be of the same political party. 2010 and terminates on December Three of the directors are directly 31, 2012. In issuing the Novem- appointed by the President, with ber Final Rule, the FDIC Board the advice and consent of the Sen- confirmed it would not extend ate, for six-year terms. One of the the FDIC’s Transaction Account three directors is designated by Guarantee Program implemented the President as Chairman for a on October 14, 2008, beyond its term of five years, and another sunset date of December 31, 2010. is designated as Vice Chairman. On December 29, 2010, President The other two Board members are Obama signed into law an amend- the Comptroller of the Currency ment to the Federal Deposit Insur- and the Director of the Office of ance Act to include Interest on Thrift Supervision. In 2011, pursu- Lawyer Trust Accounts (IOLTAs) ant to the Dodd-Frank Wall Street within the definition of noninter- Reform and Consumer Protection est-bearing transaction accounts. Act of 2010 (the Dodd-Frank Act), As a result, IOLTAs will receive the Chairman of the Consumer temporary unlimited insurance Financial Protection Bureau will be coverage at all FDIC-insured insti- added to the FDIC Board of Direc- tutions from December 31, 2010 tors and replace the Director of the through December 31, 2012. Office of Thrift Supervision. Any depository institution that The FDIC insures deposits at all receives deposits may be insured insured commercial banks and by the FDIC after application to savings institutions. On October and examination and approval by 3, 2008, the Emergency Economic the FDIC. After considering the Stabilization Act of 2008 was (1) applicant’s financial history and approved, temporarily raising the condition, (2) adequacy of the capi- standard maximum deposit insur- tal structure, (3) future earnings ance amount (SMDIA) on federal prospects, (4) general character deposit insurance coverage from of the management, (5) risk pre- $100,000 to $250,000 per deposi- sented to the insurance fund, tor through December 31, 2009. On (6) convenience and needs of the May 20, 2009, the Helping Fami- community to be served, and lies Save Their Homes Act was (7) consistency of corporate pow- approved, extending the SMDIA ers, the FDIC may approve or deny temporary increase to $250,000 an application for insurance. The per depositor through Decem- Federal Deposit Insurance Corpo- ber 31, 2013. On July 22, 2010, the ration Improvement Act of 1991 Dodd-Frank Act made perma- (FDICIA) expanded the FDIC’s nent the increase to $250,000 of the approval authority to include SMDIA. national banks, all state-chartered

24 banks that are members of the Francisco. The two area offices are industry, and to meet certain man- Federal Reserve System, and fed- located in Boston (reports to New dates in the Dodd-Frank Act, the eral and state-chartered savings York) and Memphis (reports to FDIC initiated various structural associations. Dallas). In addition to the regional changes in 2010, including the cre- and area offices, the FDIC main- ation of four new organizations. The FDIC has primary federal reg- tains eighty-five field territory ulatory and supervisory author- offices for risk management and The Office of Complex Finan- ity over insured state-chartered seventy-four field territory offices cial Institutions will oversee the banks that are not members of the for compliance, with dedicated orderly liquidation of bank hold- Federal Reserve System, and it has examiners assigned to many of the ing companies with more than the authority to examine for insur- largest financial institutions. $100 billion in assets as well as ance purposes any insured finan- significant non-bank financial cial institution, either directly or in Bank liquidations are handled companies, as determined by the cooperation with state or other fed- by the Division of Resolutions new Financial Stability Oversight eral supervisory authorities. The and Receiverships. In protect- Council, that fail. ing insured deposits, the FDIC is FDICIA gives the FDIC backup The Division of Depositor and enforcement authority over all charged with resolving the prob- lems of insured failed depository Consumer Protection will provide insured institutions; that is, the increased visibility to the FDIC’s FDIC can recommend that the institutions at the least possible cost to the deposit insurance fund. compliance examination and appropriate federal agency take enforcement program for thou- action against an insured institu- In carrying out this responsibil- ity, the FDIC engages in several sands of community banks with tion and may do so itself if deemed $10 billion or less in total assets. necessary. In addition, the Dodd- activities, including paying off Frank Act expanded the FDIC’s deposits, arranging the purchase The Office of Corporate Risk Man- authority to manage the failure of of assets and assumption of liabili- agement will strategically man- systemically significant firms. ties of failed institutions, effecting age a comprehensive program insured deposit transfers between that addresses the Corporation’s The FDIC’s supervisory activities institutions, creating and operat- emerging and crisis related risks. are conducted by the Division of ing temporary bridge banks until Supervision and Consumer Protec- a resolution can be accomplished, The Office of Minority and tion. The division is organized into and using its conservatorship Women Inclusion will be respon- six regional offices and two area powers. sible for all matters of the agency offices. The regional offices are relating to diversity in manage- located in Atlanta, Chicago, Dallas, In response to the changing risk ment, employment and business Kansas City, New York, and San profile of the Corporation and the activities.

25 National Credit Union tion Fund, a borrowing facility Administration and assessment authority for corporate credit union issues; The National Credit Union and Administration, established by the (Section • manage the Central Liquid- 1752a) of Congress in 1934, is the ity Facility, a central bank for agency that supervises the nation’s credit unions, which provides federal credit union system. A liquidity to the credit union three-member bipartisan board system. appointed by the President for six- The National Credit Union year terms manages the National Administration also has statutory Credit Union Administration. The authority to examine and super- President also selects a member to vise NCUSIF-insured, state-char- serve as Chair of the board. tered credit unions in coordina- The main responsibilities of tion with state agencies. the National Credit Union The National Credit Union Administration are the following: Administration has five regional offices across the United States • charter, examine, and supervise that administers its responsibil- more than 4,600 federal credit ity to charter and supervise credit unions nationwide; unions. Its examiners conduct on- • administer the National Credit site examinations and supervi- Union Share Insurance Fund sion of each federal credit union (NCUSIF), which insures mem- and selected state-chartered credit ber share accounts in more than unions. The National Credit 7,400 U.S. federal and state- Union Administration is funded chartered credit unions; by the credit unions it regulates and insures. • administer the Temporary Cor- porate Credit Union Stabiliza-

26 Office of the Comptroller permissible banking activities. of the Currency • Establishing and communicat- The Office of the Comptroller of ing regulations, policies, and the Currency (OCC) is the oldest operating guidance applicable Comptroller of the Currency Administrator of National Banks federal bank regulatory agency, to national banks. established as a bureau of the Trea- US Department of the Treasury • Supervising the - sury Department by the National ing system through on-site Currency Act of 1863. It is headed examinations, off-site moni- by the Comptroller of the Cur- toring, systemic risk analyses, rency, who is appointed to a five- and appropriate enforcement year term by the President with the activities. advice and consent of the Senate. The Comptroller is also a Direc- To meet its objectives, the OCC tor of the FDIC and a Director of maintains a nationwide staff of the Neighborhood Reinvestment bank examiners and other pro- Corporation. fessional and support personnel. Headquartered in Washington, The OCC was created by Congress D.C., the OCC has four district to charter, regulate, and supervise offices in Chicago, Dallas, Den- national banks. The OCC regulates ver, and New York. In addition, and supervises 1,451 national banks the OCC maintains a network and trust companies and 51 federal of 49 field offices and 22 satellite branches of foreign banks account- locations in cities throughout the ing for approximately 70 percent United States, as well as resident of the total assets of all U.S. com- examiner teams in 18 of the larg- mercial banks and branches of for- est national banking companies eign banks. In 2011, pursuant to and an examining office in Lon- the Dodd-Frank Wall Street Reform don, England. and Consumer Protection Act, the OCC will assume supervisory The Comptroller receives advice responsibility for federal savings on policy and operational issues associations, as well as rulemak- from an Executive Committee, ing authority relating to all savings comprised of senior agency offi- associations. cials who lead major business units. The OCC seeks to ensure that national banks soundly manage The OCC is funded primarily their risks, comply with applica- by semiannual assessments on ble laws, compete effectively with national banks, interest revenue other providers of financial ser- from its investment in U.S. Trea- vices, offer products and services sury securities, and other fees. The that meet the needs of customers, OCC does not receive congressio- and provide fair access to financial nal appropriations for any of its services and fair treatment of their operations. customers. The OCC’s mission-crit- ical programs include: • Chartering national banks and issuing interpretations related to

27 Office of Thrift Supervision by the President, with the advice and consent of the Senate, to The Office of Thrift Supervision serve a five-year term. The Direc- was established as a bureau of the tor determines policy for the U. S. Department of the Treasury Office of Thrift Supervision and in 1989. The Office of Thrift Super- makes final decisions on regula- vision charters and is the pri- tions governing the industry as mary regulator for all federal sav- a whole and on measures affect- ings associations, and shares joint ing individual institutions. The responsibility with state authori- Director also serves as a Director ties for supervision of all state sav- of the Federal Deposit Insurance ings associations. The Office of Corporation and as a Director of Thrift Supervision is also the pri- the Neighborhood Reinvestment mary regulator for all savings and Corporation. loan holding companies. The agency conducts its opera- The mission of the Office of Thrift tions from its headquarters in Supervision is to supervise sav- Washington, D.C., and four ings associations and their hold- regional offices located in Jer- ing companies in order to main- sey City, New Jersey (Northeast tain their safety and soundness Region); Atlanta, Georgia (South- and compliance with consumer east Region); Chicago, Illinois laws, and to encourage a competi- (Central Region); and Dallas, tive industry that meets America’s Texas (Western Region). financial service needs. The Office of Thrift Supervision The Office of Thrift Supervision uses no congressional appropria- carries out its mission by tions to fund any of its operations. (1) adopting regulations governing It draws its revenues primarily the thrift institution industry, through fees and assessments lev- (2) examining and supervising ied on the institutions it regulates. savings associations and their affiliates, (3) taking appropriate According to the provisions of the action to enforce compliance with Dodd-Frank Wall Street Reform federal laws and regulations, and and Consumer Protection Act of (4) acting on applications to char- 2010 (the Dodd-Frank Act) the ter or acquire a savings associa- Office of Thrift Supervision will tion. The Office of Thrift Super- be closed in July 2011. While most vision also has the authority to of its functions will be transferred regulate, examine, supervise, and to the Office of the Comptroller of take enforcement action against the Currency, certain other author- savings and loan holding compa- ities of the Office of Thrift Super- nies and other affiliates, as well vision will be transferred to the as entities that provide services to Federal Deposit Insurance Corpo- savings associations. ration and the Board of Governors of the Federal Reserve System. The Office of Thrift Supervision is headed by a Director appointed

28 ASSETS, LIABILITIES, AND NET WORTH of U.S. Commercial Banks, Thrift Institutions, and Credit Unions as of December 31, 20101 Billions of dollars

Thrift Institutions U.S. Branches Other Credit U.S. Commercial Banks2 and OTS-Regulated4 FDIC- Unions3 Agencies Super- State of vised State Non- Foreign Federal State Savings Federal State Item Total National Member Member Banks5 Charter Charter Banks Charter Charter

Total assets 16,143 8,432 1,694 1,938 1,912 920 12 321 500 414

Total loans and receivables (net) 8,185 4,274 833 1,269 475 563 8 205 303 255 Loans secured by real estate6 4,615 2,290 524 835 35 436 8 178 163 146 Consumer loans7 1,574 957 62 209 0 88 0 6 143 109 Commercial and industrial loans 1,431 751 182 191 236 50 0 15 2 4 All other loans and lease receivables8 805 439 89 65 203 0 0 9 0 0 LESS: Allowance for possible loan and lease losses 240 164 23 30 0 11 0 3 5 4 Federal funds sold and securities purchased under agreements to resell 547 415 21 17 87 4 0 2 0 1 Cash and due from depository institutions9 1,523 563 227 133 397 49 1 18 73 62 Securities and other obligations10 3,015 1,620 370 362 169 245 2 69 101 77 U.S. government obligations11 861 255 63 97 56 180 2 54 87 67 Obligations of state and local governments12 182 84 27 60 0 6 0 5 0 0 Other securities 1,971 1,282 279 204 113 59 0 10 14 10 Other assets13 2,873 1,560 243 158 783 59 1 27 23 19

Total liabilities 14,538 7,494 1,491 1,714 1,912 812 10 283 449 373

Total deposits and shares14 11,282 5,763 1,257 1,491 1,078 661 9 237 427 359 Federal funds purchased and securities sold under agreements to repurchase 823 419 69 40 247 38 0 10 0 0 Other borrowings15 1,504 814 93 157 280 99 1 32 18 10 Other liabilities16 928 497 72 26 307 14 0 3 4 4

Net worth17 1,607 938 203 225 2 108 2 37 51 41

Memorandum: Number of institutions reporting 15,218 1,381 817 4,316 233 670 61 398 4,589 2,750

Footnotes to Tables their foreign branches, foreign subsid- 5. These institutions are not required to iaries, branches in Puerto Rico and U.S. file reports of income. 1. The table covers institutions, including territories and possessions, and FDIC those in Puerto Rico and U.S. territories insured banks in Puerto Rico and U.S. 6. Includes loans secured by residential and possessions, insured by the Fed- territories and possessions. Excludes property, commercial property, farm- eral Deposit Insurance Corporation or bank holding companies. land (including improvements) and National Credit Union Savings Insur- unimproved land; and construction ance Fund. All branches and agencies of 3. Data are for federally insured natural loans secured by real estate. person credit unions only. foreign banks in the United States, but 7. Includes loans, except those secured excluding any in Puerto Rico and U.S. 4. Data for thrift institutions regulated by real estate, to individuals for house- territories and possessions, are covered by the OTS reflects fully consolidated hold, family, and other personal expen- whether or not insured. Excludes Edge statements of condition and operations. ditures including both installment and Act and agreement corporations that Data for OTS regulated thrifts owned single payment loans. Net of unearned are not subsidiaries of U.S. commercial directly by other thrifts are excluded to income on installment loans. banks. avoid double counting results already 2. Reflects fully consolidated statements included in the parents' financial of FDIC-insured U.S. banks—including statements. Notes continue on the next page

29 INCOME AND EXPENSES of U.S. Commercial Banks and Thrift Institutions for the Twelve Months Ending December 31, 20101 Billions of dollars

Thrift Institutions

Other Credit U.S. Commercial Banks2 OTS-Regulated4 FDIC- Unions3 Super- State vised State Non- Federal State Savings Federal State Item Total National Member Member Charter Charter Banks Charter Charter

Operating income 825 494 90 115 59 0 15 29 23 Interest and fees on loans 454 254 42 79 34 0 11 19 15 Other interest and dividend income 124 77 14 13 12 0 2 3 3 All other operating income 244 161 34 22 13 0 2 7 5

Operating expenses 702 408 82 104 48 0 13 26 21 Salaries and benefits 184 108 24 24 9 0 4 8 7 Interest on deposits and shares 77 31 8 18 8 0 3 5 4 Interest on other borrowed money 40 24 4 5 5 0 1 1 0 Provision for loan and lease losses 164 104 18 24 10 0 1 4 3 All other operating expenses 237 141 28 33 16 0 4 8 7

Net operating income 123 86 8 11 11 0 2 3 2

Securities gains and losses 9 6 1 2 0 0 0 0 0

Extraordinary Items -1 -1 0 0 0 0 0 0 0

Income taxes 38 26 3 4 4 0 1 0 0

Net income 93 65 6 8 7 0 2 3 2

Memorandum: Number of institutions reporting 14,982 1,381 817 4,316 670 61 398 4,589 2,750

8. Includes loans to financial institutions, foreign banks that do not report these possessions, and Edge Act and Agree- for purchasing or carrying securities, securities separately. Loans to states and ment corporation subsidiaries. to finance agricultural production and political subdivisions and public author- other loans to farmers (except those ities are included in “All other loans and 15. Includes interest-bearing demand notes secured by real estate), to states and lease receivables.” issued to the U.S. Treasury, borrowing political subdivisions and public author- from Federal Reserve Banks and Federal ities, and miscellaneous types of loans. 13. Customers’ liabilities on acceptances, Home Loan Banks, subordinated debt, real property owned, various accrual limited life preferred stock, and other 9. Includes vault cash, cash items in pro- accounts, and miscellaneous assets. For nondeposit borrowing. cess of collection, and balances with U.S. U.S. branches and agencies of foreign and foreign banks and other depository banks, also includes net due from head 16. Includes depository institutions’ own institutions (including demand and time office and other related institutions. For mortgage borrowing, liability for capi- deposits and certificates of deposit for SAIF-insured institutions, also includes talized leases, liability on acceptances all categories of institutions). equity investment in service corporation executed, various accrual accounts, subsidiaries. and miscellaneous liabilities. For U.S. 10. Includes government and corporate branches and agencies of foreign banks, securities, including mortgage-backed 14. Includes demand, savings, and time also includes net owed to head office securities and obligations of states and deposits, (including certificates of and other related institutions. political subdivisions and of U.S. gov- deposit at commercial banks, U.S. ernment agencies and corporations. branches and agencies of foreign banks, 17. Includes capital stock, surplus, capital and savings banks), credit balances at reserves, and undivided profits. 11. U.S. Treasury securities and securities of, U.S. agencies of foreign banks and share and loans to, U.S. government agencies balances at savings and loan associa- and corporations. tions and credit unions (including cer- NOTE: Data are rounded to nearest bil- lion. Consequently, some information 12. Securities issued by states and political tificates of deposit, NOW accounts, and may not reconcile precisely. Addition- subdivisions and public authorities, share draft accounts). For U.S. commer- ally, balances less than $500 million will except for savings and loan associa- cial banks, includes deposits in foreign show as zero. tions and U.S. branches and agencies of offices, branches in U.S. territories and

30 APPENDIX A: RELEVA N T STATUTES

Federal Financial Institutions and loan association, a home- (c) Term of office Examination Council Act stead association, a cooperative bank, or a credit union. The term of the Chairman of the 12 U.S.C. § 3301. Declaration of Council shall be two years. purpose 12 U.S.C. § 3303. Financial (d) Designation of officers and It is the purpose of this chapter to Institutions Examination Council employees establish a Financial Institutions (a) Establishment; composition The members of the Council may, Examination Council which shall from time to time, designate other prescribe uniform principles and There is established the Financial officers or employees of their standards for the Federal exami- Institutions Examination Council respective agencies to carry out nation of financial institutions which shall consist of— their duties on the Council. by the Office of the Comptrol- (1) the Comptroller of the ler of the Currency, the Federal (e) Compensation and expenses Currency, Deposit Insurance Corporation, Each member of the Council shall the Board of Governors of the Fed- (2) the Chairman of the Board serve without additional compen- eral Reserve System, the Federal of Directors of the Federal sation but shall be entitled to rea- Home Loan Bank Board, and the Deposit Insurance Corporation, sonable expenses incurred while National Credit Union Adminis- carrying out his official duties as tration and make recommenda- (3) a Governor of the Board such a member. tions to promote uniformity in of Governors of the Federal the supervision of these financial Reserve System designated by institutions. The Council’s actions the Chairman of the Board, 12 U.S.C. § 3304. Costs and expenses of Council shall be designed to promote con- (4) the Director of the sistency in such examination and Consumer Financial Protection One-fifth of the costs and expenses to insure progressive and vigilant Bureau,1 of the Council, including the sala- supervision. ries of its employees, shall be paid (5) the Chairman of the by each of the Federal financial National Credit Union 12 U.S.C. § 3302. Definitions institutions regulatory agencies. Administration Board; and Annual assessments for such share As used in this chapter— (6) the Chairman of the State shall be levied by the Council (1) the term “Federal finan- Liaison Committee based upon its projected budget for the year, and additional assess- cial institutions regulatory agen- (b) Chairmanship cies” means the Office of the ments may be made during the Comptroller of the Currency, the The members of the Council shall year, if necessary. Board of Governors of the Fed- select the first chairman of the eral Reserve System, the Federal Council. Thereafter the chairman- 12 U.S.C. § 3305. Functions of Deposit Insurance Corporation, ship shall rotate among the mem- Council the Office of Thrift Supervision, bers of the Council. (a) Establishment of principles and the National Credit Union and standards Administration; 1. The Dodd Frank Wall Street Reform The Council shall establish uni- (2) the term “Council” means and Consumer Protection Act of 2010 form principles and standards the Financial Institutions Exami- amended several provisions in the rel- and report forms for the examina- nation Council; and evant statutes, including excerpts con- tion of financial institutions which tained in this appendix. Changes are shall be applied by the Federal (3) the term “financial institu- shown as bolded and italicized. The amendments relating to the Consumer financial institutions regulatory tion” means a commercial bank, Financial Protection Bureau are not agencies. a savings bank, a trust company, effective until the designated transfer a savings association, a building date (currently July 21, 2011). (b) Making recommendations

31 regarding supervisory matters and The Council shall conduct schools twice a year with the Council. adequacy of supervisory tools for examiners and assistant exam- Members of the liaison com- iners employed by the Federal mittee shall receive a reasonable (1) The Council shall make financial institutions regulatory allowance for necessary expenses recommendations for uniformity agencies. Such schools shall be incurred in attending meetings. in other supervisory matters, open to enrollment by employ- such as, but not limited to, clas- ees of State financial institu- Members of the Liaison Commit- sifying loans subject to country tions supervisory agencies and tee shall elect a chairperson from risk, identifying financial insti- employees of the Federal Housing among the members serving on tutions in need of special super- Finance Board under conditions the committee. visory attention, and evaluat- specified by the Council. ing the soundness of large loans 12 U.S.C. § 3307. Administration that are shared by two or more (e) Affect on Federal regula- financial institutions. In addi- tory agency research and develop- (a) Authority of Chairman of tion, the Council shall make rec- ment of new financial institutions Council supervisory agencies ommendations regarding the The Chairman of the Council is adequacy of supervisory tools Nothing in this chapter shall be authorized to carry out and to for determining the impact of construed to limit or discour- delegate the authority to carry out holding company operations on age Federal regulatory agency the internal administration of the the financial institutions within research and development of new Council, including the appoint- the holding company and shall financial institutions supervisory ment and supervision of employ- consider the ability of supervi- methods and tools, nor to pre- ees and the distribution of busi- sory agencies to discover pos- clude the field testing of any inno- ness among members, employees, sible fraud or questionable and vation devised by any Federal reg- and administrative units. illegal payments and practices ulatory agency. which might occur in the opera- (b) Use of personnel, services, tion of financial institutions or (f) Annual report and facilities of Federal financial their holding companies. institutions regulatory agencies, Not later than April 1 of each Federal Reserve banks, and Fed- year, the Council shall prepare an (2) When a recommendation eral Home Loan Banks. of the Council is found unac- annual report covering its activi- ceptable by one or more of the ties during the preceding year. In addition to any other authority applicable Federal financial conferred upon it by this chapter, (g) Flood insurance institutions regulatory agencies, in carrying out its functions under the agency or agencies shall sub- The Council shall consult with this chapter, the Council may uti- mit to the Council, within a time and assist the Federal entities for lize, with their consent and to the period specified by the Coun- lending regulation, as such term extent practical, the personnel, cil, a written statement of the is defined in section 4121(a) of services, and facilities of the Fed- reasons the recommendation is Title 42, in developing and coor- eral financial institutions regula- unacceptable. dinating uniform standards and tory agencies, Federal Reserve requirements for use by regulated banks, and Federal Home Loan (c) Development of uniform lending institutions under the Banks, with or without reim- reporting system national flood insurance bursement therefore. program. The Council shall develop uniform (c) Compensation, authority, reporting systems for federally and duties of officers and employ- supervised financial institutions, 12 U.S.C. § 3306. State liaison ees; experts and consultants their holding companies, and non- financial institution subsidiaries of To encourage the application of In addition, the Council may— such institutions or holding com- uniform examination principles panies. The authority to develop and standards by State and Fed- (1) subject to the provisions uniform reporting systems shall eral supervisory agencies, the of Title 5 relating to the com- not restrict or amend the require- Council shall establish a liaison petitive service, classification, ments of section 78l(i) of Title 15. committee composed of five rep- and General Schedule pay resentatives of State agencies rates, appoint and fix the com- (d) Conducting schools for which supervise financial insti- pensation of such officers and examiners and assistant examiners tutions which shall meet at least employees as are necessary to

32 carry out the provisions of this 12 U.S.C. § 3310. Establishment of (2) at regular intervals, pro- chapter, and to prescribe the Appraisal Subcommittee vide notice and solicit public authority and duties of such comment on a particular cate- There shall be within the Council a officers and employees; and gory or categories of regulations, subcommittee to be known as the (2) obtain the services of such requesting commentators to “Appraisal Subcommittee,” which experts and consultants as are identify areas of the regulations shall consist of the designees of necessary to carry out the provi- that are outdated, unnecessary, the heads of the Federal financial sions of this chapter. or unduly burdensome. institutions regulatory agencies, the Bureau of Consumer Finan- (c) Complete review 12 U.S.C. § 3308. Access to books, cial Protection, and the Federal accounts, records, etc., by Council Housing Finance Agency. Each The Council or the appropri- such designee shall be a person ate Federal banking agency shall For the purpose of carrying out ensure that the notice and com- this chapter, the Council shall who has demonstrated knowl- edge and competence concern- ment period described in sub- have access to all books, accounts, section (b)(2) of this section is records, reports, files, memoran- ing the appraisal profession. At all times at least one member of conducted with respect to all regu- dums, papers, things, and prop- lations described in subsection (a) erty belonging to or in use by the Appraisal Subcommittee shall have demonstrated knowledge of this section not less frequently Federal financial institutions than once every 10 years. regulatory agencies, including and competence through licen- reports of examination of finan- sure, certification, or professional (d) Regulatory response cial institutions or their holding designation within the appraisal The Council or the appropriate companies from whatever source, profession. Federal banking agency shall— together with workpapers and correspondence files related to 12 U.S.C. § 3311. Required review of (1) publish in the Federal Reg- such reports, whether or not a regulations ister a summary of the com- part of the report, and all without (a) In general ments received under this sec- any deletions. tion, identifying significant Not less frequently than once issues raised and providing every 10 years, the Council and comment on such issues; and 12 U.S.C. § 3309. Risk management each appropriate Federal banking training agency represented on the Council (2) eliminate unnecessary reg- (a) Seminars shall conduct a review of all regu- ulations to the extent that such lations prescribed by the Council action is appropriate. The Council shall develop and or by any such appropriate Fed- (e) Report to Congress administer training seminars in eral banking agency, respectively, risk management for its employ- in order to identify outdated or Not later than 30 days after car- ees and the employees of insured otherwise unnecessary regulatory rying out subsection (d)(1) of this financial institutions. requirements imposed on insured section, the Council shall submit (b) Study of risk management depository institutions. to the Congress a report, which training program (b) Process shall include— Not later than end of the 1-year In conducting the review under (1) a summary of any signifi- period beginning on August 9, subsection (a) of this section, the cant issues raised by public com- 1989, the Council shall— Council or the appropriate Federal ments received by the Council banking agency shall— and the appropriate Federal (1) conduct a study on the fea- banking agencies under this sec- sibility and appropriateness of (1) categorize the regulations tion and the relative merits of establishing a formalized risk described in subsection (a) of such issues; and management training program this section by type (such as con- designed to lead to the certifica- sumer regulations, safety and (2) an analysis of whether tion of Risk Management Ana- soundness regulations, or such the appropriate Federal bank- lysts; and other designations as deter- ing agency involved is able to mined by the Council, or the address the regulatory burdens (2) report to the Congress the appropriate Federal banking associated with such issues by results of such study. agency); and regulation, or whether such bur-

33 dens must be addressed by leg- report to the Congress not reports, at the call of the Chairper- islative action. later than June 15 of each year son or a majority of its members that describes the manner in when there is business to be con- which each function assigned ducted. A majority of members of Excerpts from Statute to the Appraisal Subcommit- the Appraisal Subcommittee shall Governing Appraisal tee has been carried out during constitute a quorum but 2 or more Subcommittee the preceding year. The report members may hold hearings. Deci- shall also detail the activities sions of the Appraisal Subcom- 12 U.S.C. § 3332. Functions of of the Appraisal Subcommit- mittee shall be made by the vote Appraisal Subcommittee tee, including the results of all of a majority of its members. The audits of State appraiser regu- subject matter discussed in any (a) In general latory agencies, and provide closed or executive session shall be The Appraisal Subcommittee an accounting of disapproved described in the Federal Register shall— actions and warnings taken notice of the meeting. in the previous year, includ- (1) monitor the requirements ing a description of the condi- established by States— tions causing the disapproval Excerpts from Home Mortgage (A) for the certification and actions taken to achieve Disclosure Act and licensing of individuals compliance. who are qualified to perform 12 U.S.C. § 2801. Congressional (6) maintain a national reg- findings and declaration of purpose appraisals in connection with istry of appraisal management federally related transac- companies that either are regis- (a) Findings of Congress tions, including a code of tered with and subject to super- The Congress finds that some professional responsibility; vision of a State appraiser cer- and depository institutions have some- tifying and licensing agency or times contributed to the decline of (B) for the registration and are operating subsidiaries of a certain geographic areas by their supervision of the operations Federally regulated financial failure pursuant to their charter- and activities of an appraisal institution. ing responsibilities to provide ade- management company; and (b) Monitoring and reviewing quate home financing to qualified (2) monitor the requirements Foundation applicants on reasonable terms and conditions. established by the Federal The Appraisal Subcommittee shall financial institutions regula- monitor and review the practices, (b) Purpose of chapter tory agencies with respect to— procedures, activities, and organi- The purpose of this chapter is to (A) appraisal standards for zational structure of the Appraisal provide the citizens and public federally related transactions Foundation. officials of the United States with under their jurisdiction, and sufficient information to enable 12 U.S.C. § 3333. Chairperson of them to determine whether depos- (B) determinations as to Appraisal Subcommittee; term of itory institutions are filling their which federally related trans- Chairperson; meetings obligations to serve the housing actions under their jurisdic- needs of the communities and tion require the services of a (a) Chairperson neighborhoods in which they are State certified appraiser and located and to assist public offi- which require the services of The Council shall select the Chair- cials in their determination of the a State licensed appraiser; person of the subcommittee. The term of the Chairperson shall be distribution of public sector invest- (3) maintain a national reg- two years. ments in a manner designed to istry of State certified and improve the private investment licensed appraisers who are eli- (b) Meetings; quorum; voting environment. gible to perform appraisals in The Appraisal Subcommittee shall (c) Construction of chapter federally related transactions; meet in public session after notice and in the Federal Register, but may Nothing in this chapter is intended to, nor shall it be construed to, (4) Omitted. close certain portions of these meetings related to personnel and encourage unsound lending prac- (5) transmit an annual review of preliminary State audit tices or the allocation of credit.

34 12 U.S.C. § 2803. Maintenance of this title or which are exempt pur- requirements for State-licensed records and public disclosure suant to section 2805(b) of this title. loan originators. The Council shall also produce (f) Data disclosure system; oper- tables indicating, for each primary (2) Provides a comprehen- ation, etc. metropolitan statistical area, met- sive licensing and supervisory database. The Federal Financial Institutions ropolitan statistical area, or consol- Examination Council, in consul- idated metropolitan statistical area (3) Aggregates and improves tation with the Secretary, shall that is not comprised of designated the flow of information to and implement a system to facilitate primary metropolitan statistical between regulators. areas, aggregate lending patterns access to data required to be dis- (4) Provides increased closed under this section. Such for various categories of census tracts grouped according to loca- accountability and tracking of system shall include arrange- loan originators. ments for a central depository of tion, age of housing stock, income data in each primary metropoli- level, and racial characteristics. (5) Streamlines the licensing tan statistical area, metropolitan (b) Staff and data processing process and reduces the regula- statistical area, or consolidated resources tory burden. metropolitan statistical area that (6) Enhances consumer pro- is not comprised of designated The Board shall provide staff and tections and supports anti-fraud primary metropolitan statistical data processing resources to the measures. areas. Disclosure statements shall Council to enable it to carry out be made available to the pub- the provisions of subsection (a) of (7) Provides consumers with lic for inspection and copying at this section. easily accessible information, such central depository of data for offered at no charge, utilizing (c) Availability to public all depository institutions which electronic media, including the are required to disclose informa- The data and tables required pur- Internet, regarding the employ- tion under this section (or which suant to subsection (a) of this sec- ment history of, and publicly are exempted pursuant to section tion shall be made available to the adjudicated disciplinary and 2805(b) of this title) and which public no later than December 31 enforcement actions against, have a home office or branch office of the year following the calendar loan originators. within such primary metropolitan year on which the data is based. statistical area, metropolitan sta- (8) Establishes a means by tistical area, or consolidated met- which residential mortgage loan ropolitan statistical area that is not originators would, to the great- comprised of designated primary Excerpts from S.A.F.E. est extent possible, be required metropolitan statistical areas. Mortgage Licensing Act to act in the best interests of the consumer. 12 U.S.C. § 5101. Purposes and 12 U.S.C. § 2809. Compilation of methods for establishing a mortgage (9) Facilitates responsible aggregate data licensing system and registry behavior in the subprime mort- gage market place and pro- (a) Commencement; scope of In order to increase uniformity, vides comprehensive training data and tables reduce regulatory burden, enhance and examination requirements consumer protection, and reduce Beginning with data for calendar related to subprime mortgage fraud, the States, through the Con- lending. year 1980, the Federal Financial ference of State Bank Supervisors Institutions Examination Council and the American Association of (10) Facilitates the collec- shall compile each year, for each Residential Mortgage Regulators, tion and disbursement of con- primary metropolitan statistical are hereby encouraged to establish sumer complaints on behalf area, metropolitan statistical area, a Nationwide Mortgage Licens- of State and Federal mortgage or consolidated metropolitan sta- ing System and Registry for the regulators. tistical area that is not comprised residential mortgage industry that of designated primary metropoli- accomplishes all of the following 12 U.S.C. § 5106. System of tan statistical areas, aggregate data objectives: registration administration by by census tract for all depository Federal agencies institutions which are required to (1) Provides uniform license disclose data under section 2803 of applications and reporting (a) Development

35 (1) In general rized to receive such informa- To facilitate the transfer of infor- tion for a State and national mation required by subsection The Bureau shall develop and criminal history background (a)(2), the Nationwide Mortgage maintain a system for registering check; and Licensing System and Registry employees of a depository insti- shall coordinate with the Federal tution, employees of a subsid- (B) personal history and banking agencies, through the iary that is owned and controlled experience, including autho- Financial Institutions Examina- by a depository institution and rization for the Nationwide tion Council, and the Farm Credit regulated by a Federal banking Mortgage Licensing System Administration concerning the agency, or employees of an institu- and Registry to obtain infor- development and operation, by tion regulated by the Farm Credit mation related to any admin- such System and Registry, of the Administration, as registered istrative, civil or criminal find- registration functionality and data loan originators with the Nation- ings by any governmental requirements for loan originators. wide Mortgage Licensing System jurisdiction. and Registry. The system shall be (c) Consideration of factors and implemented before the end (b) Coordination procedures of the 1-year period beginning on (1) Unique identifier In establishing the registration the date of enactment of the Con- procedures under subsection (a) sumer Financial Protection Act The Federal banking agencies, and and the protocols for assigning a of 2010. the Bureau of Consumer Finan- unique identifier to a registered cial Protection shall coordinate loan originator, the Federal bank- (2) Registration requirements with the Nationwide Mortgage ing agencies shall make such de Licensing System and Registry to In connection with the registra- minimis exceptions as may be establish protocols for assigning a tion of any loan originator under appropriate to paragraphs (1)(A) unique identifier to each registered this subsection, the Bureau shall, and (2) of section 5103(a) of this loan originator that will facilitate at a minimum, furnish or cause to title, shall make reasonable efforts electronic tracking and uniform be furnished to the Nationwide to utilize existing information to identification of, and public access Mortgage Licensing System and minimize the burden of register- to, the employment history of and Registry information concern- ing loan originators, and shall publicly adjudicated disciplinary ing the identity of the employee, consider methods for automating and enforcement actions against including— the process to the greatest extent loan originators. (A) fingerprints for submis- practicable consistent with the sion to the Federal Bureau of (2) Nationwide Mortgage purposes of this title. Investigation, and any govern- Licensing System and Registry mental agency or entity autho- development

36 APPENDIX B: 2010 AUDIT REPORT

Deloitte & Touche LLP

Suite 800 1750 Tysons Boulevard McLean, VA 22102-4219 USA

Tel: +1 703 251 1000 Fax: +1 703 251 3400 www.deloitte.com INDEPENDENT AUDITORS' REPORT

To the Federal Financial Institutions Examination Council:

We have audited the accompanying balance sheets of the Federal Financial Institutions Examination Council (the “Council”) as of December 31, 2010 and 2009, and the related statements of revenues and expenses and changes in cumulative results of operations, and cash flows for the years then ended. These financial statements are the responsibility of the Council’s management. Our responsibility is to express an opinion on these financial statements based on our audits.

We conducted our audits in accordance with auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes consideration of internal control over financial reporting as a basis for designing audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Council’s internal control over financial reporting. Accordingly, we express no such opinion. An audit also includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audits provide a reasonable basis for our opinion.

In our opinion, such financial statements present fairly, in all material respects, the financial position of the Federal Financial Institutions Examination Council as of December 31, 2010 and 2009, and the results of its operations and its cash flows for the years then ended in conformity with accounting principles generally accepted in the United States of America.

In accordance with Government Auditing Standards, we have also issued our report dated February 28, 2011, on our consideration of the Council’s internal control over financial reporting and our tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements and other matters. The purpose of that report is to describe the scope of our testing of internal control over financial reporting and compliance and the results of that testing, and not to provide an opinion on the internal control over financial reporting or on compliance. That report is an integral part of an audit performed in accordance with Government Auditing Standards and should be considered in assessing the results of our audit.

February 28, 2011

37 FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL Balance Sheets

As of December 31, 2010 2009

ASSETS CURRENT ASSETS

Cash $ 746,815 $ 1,022,700 Accounts receivable from member organizations 1,276,250 1,001,002 Other accounts receivable—net 104,441 90,628

Total current assets 2,127,506 2,114,330

NONCURRENT ASSETS

Furniture and equipment—at cost 219,484 118,390 Central Data Repository software—at cost 19,371,661 18,231,272 Home Mortgage Disclosure Act Software—at cost 2,783,868 2,344,680 Less accumulated depreciation (12,704,895) (10,827,552)

Net capital assets 9,670,118 9,866,790

TOTAL ASSETS $ 11,797,624 $ 11,981,120

LIABILITIES AND CUMULATIVE RESULTS OF OPERATIONS

CURRENT LIABILITIES

Accounts payable and accrued liabilities payable to member organizations $ 839,152 $ 981,180 Other accounts payable and accrued liabilities 988,059 927,051 Accrued annual leave 27,746 20,117 Capital lease payable 37,828 16,815 Deferred revenue 2,746,667 1,856,180

Total current liabilities 4,639,452 3,801,343

LONG-TERM LIABILITIES

Capital lease payable 142,202 80,576 Deferred revenue 6,746,128 7,913,219 Deferred rent 6,605 –

Total long-term liabilities 6,894,935 7,993,795

Total liabilities 11,534,387 11,795,138

CUMULATIVE RESULTS OF OPERATIONS 263,237 185,982

TOTAL LIABILITIES AND CUMULATIVE RESULTS OF OPERATIONS $ 11,797,624 $ 11,981,120

See notes to financial statements.

38 FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL Statements of Revenues and Expenses and Changes in Cumulative Results of Operations

For the years ended December 31, 2010 2009 REVENUES

Assessments on member organizations $ 632,344 $ 589,988 Central Data Repository 4,452,286 5,741,157 Home Mortgage Disclosure Act 3,433,075 3,071,973 Tuition 2,662,193 2,322,041 Community Reinvestment Act 1,024,844 1,013,110 Uniform Bank Performance Report 464,633 537,606

Total revenues 12,669,375 13,275,875

EXPENSES

Data processing 4,529,275 4,370,506 Professional fees 3,635,374 3,674,379 Salaries and related benefits 1,739,031 1,468,414 Depreciation 1,877,343 2,943,660 Rental of office space 264,989 247,648 Administration fees 245,000 245,000 Travel 170,404 156,742 Books and subscriptions 1,656 18,985 Other seminar expenses 30,297 33,343 Rental and maintenance of office equipment 48,313 50,967 Office and other supplies 25,033 14,107 Printing 18,380 19,342 Postage 1,660 1,960 Miscellaneous 5,365 6,011

Total expenses 12,592,120 13,251,064

RESULTS OF OPERATIONS 77,255 24,811

CUMULATIVE RESULTS OF OPERATIONS—Beginning of year 185,982 161,171

CUMULATIVE RESULTS OF OPERATIONS—End of year $ 263,237 $ 185,982

See notes to financial statements.

39 FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL Statements of Cash Flows

For the years ended December 31, 2010 2009

CASH FLOWS FROM OPERATING ACTIVITIES

Results of operations $ 77,255 $ 24,811 Adjustments to reconcile results of operations to net cash provided by operating activities: Depreciation 1,877,343 2,943,660 (Increase) decrease in assets: Accounts receivable from member organizations (275,247) 571,133 Other accounts receivable (13,812) 14,995 Increase (decrease) in liabilities: Accounts payable and accrued liabilities payable to member organizations (77,379) (319,538) Other accounts payable and accrued liabilities (162,453) 642,017 Accrued annual leave 7,629 (1,891) Deferred revenue (current and non-current) (276,603) (199,161) Deferred rent 6,605 –

Net cash provided by operating activities 1,163,338 3,676,026

CASH FLOWS FROM INVESTING ACTIVITIES

Capital expenditures (1,427,853) (3,362,003)

CASH FLOWS FROM FINANCING ACTIVITIES

Capital lease payments (11,370) –

NET (DECREASE) INCREASE IN CASH (275,885) 314,023

CASH BALANCE—Beginning of year 1,022,700 708,677

CASH BALANCE—End of year $ 746,815 $ 1,022,700

See notes to financial statements.

40 Notes to Financial Statements as of and for ples generally accepted in the United States of revenues and expenses during the reporting the Years Ended December 31, 2010 and 2009 America (GAAP). period. Actual results could differ from those estimates. 1. Organization and Purpose Revenues—Assessments are made on member organizations to fund the Council's operations Allowance for Doubtful Accounts—Accounts The Federal Financial Institutions Examina- based on expected cash needs. Amounts over- receivable for non-members are shown net tion Council (the “Council”) was established or under- assessed due to differences between of the allowance for doubtful accounts. under Title X of the Financial Institutions Reg- actual and expected cash needs are presented Accounts receivable considered uncollectible ulatory and Interest Rate Control Act of 1978. in the “Cumulative Results of Operations” are charged against the allowance account in The purpose of the Council is to prescribe line item during the year and then are used to the year they are deemed uncollectible. The uniform principles and standards for the fed- offset or increase the next year’s assessment. allowance for doubtful accounts is adjusted eral examination of financial institutions and Deficits in “Cumulative Results of Opera- monthly, based upon a review of outstanding to make recommendations to promote uni- tions” can be recouped in the following year’s receivables. formity in the supervision of these financial assessments. institutions. The five agencies which were rep- 3. Transactions with Member Organizations resented on the Council during 2010, referred The Council provides seminars in the Wash- to hereinafter as member organizations, are ington, D.C., area and at locations through- 2010 2009 as follows: out the country for member organizations Accounts Receivable and other agencies. The Council also coordi- Board of Governors of the Federal Reserve Board of Governors of nates the production and distribution of the the Federal System (FRB) Uniform Bank Performance Reports (UBPR) Federal Deposit Insurance Corporation Reserve System $ 290,047 $ 209,922 through the FDIC. Tuition and UBPR revenue Federal Deposit (FDIC) is adjusted at year-end to match expenses National Credit Union Administration Insurance incurred as a result of providing education Corporation 467,726 439,609 (NCUA) classes and UBPR services. For differences Office of the Comptroller of the Currency National Credit Union between revenues and expenses, member Administration 47,501 48,593 (OCC) agencies are assessed an additional amount Office of Thrift Supervision (OTS) Office of the or credited a refund based on each member’s Comptroller of proportional cost for the Examiner Educa- In accordance with the Financial Services the Currency 416,572 244,883 tion and UBPR budget. The Council also rec- Regulatory Relief Act of 2006, a representa- Office of Thrift ognizes revenue from member agencies for tive state regulator was added as a full voting Supervision 54,404 57,995 expenses incurred related to the Community member of the Council in October 2006. Reinvestment Act. $ 1,276,250 $ 1,001,002

The Council was given additional statutory Capital Assets—Furniture and equipment is Accounts Payable and responsibilities by section 340 of the Housing recorded at cost less accumulated deprecia- Accrued Liabilities and Community Development Act of 1980, tion. Depreciation is calculated on a straight- Public Law 96-399. Among these responsi- line basis over the estimated useful lives of Board of Governors of bilities are the implementation of a system to the assets, which range from four to ten years. the Federal facilitate public access to data that depository Upon the sale or other disposition of a depre- Reserve System $ 579,792 $ 618,861 institutions must disclose under the Home ciable asset, the cost and related accumulated Federal Deposit Mortgage Disclosure Act of 1975 (HMDA) and depreciation are removed and any gain or Insurance the aggregation of annual HMDA data, by loss is recognized. The Central Data Reposi- Corporation 126,265 247,870 census tract, for each metropolitan statistical tory (CDR) and the HMDA rewrite, internally National Credit Union area. developed software projects, are recorded Administration 7,624 20,877 at cost as required by the Internal Use Soft- Office of the On July 21, 2010, the Dodd-Frank Wall Street ware Topic of Financial Accounting Stan- Comptroller of Reform and Consumer Protection Act of 2010 dards Board (FASB) Accounting Standards the Currency 124,321 72,103 (Dodd-Frank Act) was signed into law. This Codification. Office of Thrift legislation substitutes the director of the Con- Supervision 1,150 21,469 sumer Financial Protection Bureau for the Deferred Revenue—Deferred revenue includes $ 839,152 $ 981,180 director of the Office of Thrift Supervision as a cash collected and accounts receivable primar- member of the Council effective July 21, 2011. ily related to the CDR and HMDA. Operations The Council’s financial statements do not Deferred Rent—The lease for office and class- Assessments to member include financial data for the Council’s room space contains scheduled rent increases organizations for Appraisal Subcommittee (the Subcommittee). over the term of the lease. As required by the operating The Subcommittee was created pursuant to Leases Topic of the FASB Accounting Stan- expenses $ 632,344 $ 589,988 Public Law 101–73, Title XI of the Financial dards Codification, rent abatements and FRB provided Institutions Reform, Recovery, and Enforce- scheduled rent increases must be considered administrative ment Act of 1989. Although it is a subcommit- in determining the annual rent expense to be support services tee of the Council, the Appraisal Subcommit- recognized. The deferred rent represents the to the Council at tee maintains separate financial records and difference between the actual lease payments an expense of 245,000 245,000 administrative processes. The Council is not and the rent expense recognized. Member organizations responsible for any debts incurred by the Sub- provide data processing Estimates—The preparation of financial state- committee, nor are Subcommittee funds avail- services to the ments in conformity with GAAP requires able for use by the Council. Council at an management to make estimates and assump- expense of 4,529,275 4,370,506 2. Significant Accounting Policies tions that affect the reported amounts of assets and liabilities and the disclosure of contingent The Council prepares its financial state- assets and liabilities at the date of the finan- ments in accordance with accounting princi- cial statements and the reported amounts of Notes continue on the following page.

41 The Council does not directly employ person- Less revenue the production and nel, but rather member organizations detail recognized (1,856,180) (2,943,660) distribution of reports personnel to support Council operations. under the HMDA $ 2,537,870 $ 2,234,514 Ending balance $ 6,708,927 $ 7,424,719 These personnel are paid through the pay- roll systems of member organizations. Sala- The Council recognized ries and fringe benefits, including retirement Current portion the following revenue benefit plan contributions, are reimbursed to deferred revenue $ 2,236,309 $ 1,856,180 from the Department these organizations. The Council does Long-term of Housing and Urban not have any post-retirement or post- deferred revenue 4,472,618 5,568,539 Development's partici- employment benefit liabilities since Coun- pation in the HMDA cil personnel are included in the plans of the Total Deferred project 588,421 559,151 Revenue $ 6,708,927 $ 7,424,719 member organizations. The Council recognized Member organizations are not reimbursed for Total CDR Revenue the following revenue the costs of personnel who serve as Council from the Mortgage members and on the various task forces and Revenue $ 1,856,180 $ 2,943,660 Insurance Companies committees of the Council. The value of these Hosting and of America for contributed services is not included in the maintenance performing accompanying financial statements. revenue 2,596,106 2,797,497 HMDA-related work 306,784 278,308 Total CDR Revenue $ 4,452,286 $ 5,741,157 Total HMDA $ 3,433,075 $ 3,071,973 4. Central Data Repository Software

Professionsl Fees In 2003, the Council entered into an agree- Depreciation ment with UNISYS to enhance the methods Hosting and and systems used to collect, validate, process, maintenance fees Depreciation for the and distribute Call Report information, and for the CDR HMDA Rewrite project $ 2,596,106 $ 2,797,497 to store this information in a Central Data project $ 0 $ 0 Repository (CDR). Depreciation The CDR was placed into service in October Average monthly Depreciation for the depreciation $ 0 $ 0 2005. At that time, the Council began depre- CDR project $ 1,856,180 $ 2,943,660 ciating the CDR project on the straight-line basis over its estimated useful life of 6. Operating Leases 63 months. In 2009, the Council reevalu- Average monthly depreciation $ 154,682 $ 245,305 The FRB, on behalf of the Council, entered ated the useful life of CDR and decided to extend the estimated useful life by an addi- into two operating leases at market value to tional 36 months based on enhanced func- 5. Home Mortgage Disclosure Act Software secure office and classroom space. One lease tionality of the software. The Council records terminated in 2009 and one began in January The Council entered into an agreement with depreciation expenses and recognizes the 2010 with the FDIC. FRB to maintain and support the HMDA pro- same amount of revenue. The value of the cessing system. In 2007, the Council began a Years ending December 31 Amount CDR asset as of December 31, 2010 and 2009, rewrite of the entire HMDA processing sys- includes the fully accrued and paid cost. 2011 $ 261,598 tem. The HMDA rewrite will enhance the 2012 264,900 2010 2009 processing system. The cost of the software 2013 268,292 Capital Asset CDR in process is $2,783,868 and $2,344,680 as of 2014 271,772 December 31, 2010 and 2009, respectively. The Beginning balance $18,231,272 $14,140,655 financial activity associated with the process- Total minimum lease payments $ 1,066,562 Software placed in ing system for the years ended December 31, use during the 2010 and 2009, is as follows. Rental expenses under these operating leases year 1,140,389 4,090,617 were $264,989 and $247,648 as of December 2010 2009 31, 2010 and 2009, respectively. Total asset $19,371,661 $18,231,272 Deferred Revenue

Beginning balance $ 2,344,680 1,544,895 7. Capital Leases Accounts payable and Additions 439,188 799,785 accrued liabilities In December 2009 and November 2010, related to CDR Less revenue the Council entered into capital leases for recognized 0 0 printing equipment. Furniture and equipment Payable to UNISYS Ending balance $ 2,783,868 $ 2,344,680 includes $198,485 for the capital leases. for the CDR Contingent rentals for excess usage of the project $ 865,630 $ 729,166 Current portion printing equipment amounted to $11,049 in deferred revenue $ 556,774 $ 0 2010. Revenues—Central Data Repository—The Coun- Long-term deferred The future minimum lease payments required cil is funding the project by billing the three revenue 2,227,094 2,344,680 under the capital leases and the present value participating Council member organizations of the net minimum lease payments as of Total Deferred (FRB, FDIC, and OCC). Funding for the years December 31, 2010, are as follows: Revenue $ 2,783,868 $ 2,344,680 ended December 31, 2010 and 2009, is as follows. Years ending December 31 Amount Revenue 2010 2009 2011 $ 59,089 Deferred Revenue The Council recognized 2012 59,089 the following revenue 2013 59,089 Beginning balance $ 7,424,718 $ 8,173,666 from member 2014 59,089 Additions 1,140,389 2,194,713 organizations for 2015 31,737

42 Total minimum lease 8. Subsequent Events payments 268,093 There were no subsequent events that Less amount representing require adjustments to or disclosures in maintenance (72,789) the financial statements as of December 31, 2010. Subsequent events were evaluated Net minimum lease payments 195,304 through February 28, 2011, which is the date the financial statements were available to be Less amount representing interest (15,274) issued.

Net minimum lease payments 180,030

Less current maturities of capital lease payments (37,828)

Long-term capital lease obligations $ 142,202

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Deloitte & Touche LLP Suite 800 1750 Tysons Boulevard McLean, VA 22102-4219 USA

Tel: +1 703 251 1000 Fax: +1 703 251 3400 www.deloitte.com

INDEPENDENT AUDITORS’ REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS

To the Federal Financial Institutions Examination Council:

We have audited the financial statements of the Federal Financial Institutions Examination Council (the “Council”) as of and for the year ended December 31, 2010, and have issued our report thereon dated February 28, 2011. We conducted our audit in accordance with auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States.

Internal Control over Financial Reporting

In planning and performing our audit, we considered the Council’s internal control over financial reporting as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements, but not for the purpose of expressing an opinion on the effectiveness of the Council’s internal control over financial reporting. Accordingly, we do not express an opinion on the effectiveness of the Council’s internal control over financial reporting.

A control deficiency exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A significant deficiency is a control deficiency, or combination of control deficiencies, that adversely affects the entity's ability to initiate, authorize, record, process, or report financial data reliably in accordance with generally accepted accounting principles such that there is more than a remote likelihood that a misstatement of the Council’s financial statements that is more than inconsequential will not be prevented or detected by the Council’s internal control.

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A material weakness is a significant deficiency, or combination of significant deficiencies, that results in more than a remote likelihood that a material misstatement of the financial statements will not be prevented or detected by the Council’s internal control.

Our consideration of internal control over financial reporting was for the limited purpose described in the first paragraph of this section and would not necessarily identify all deficiencies in internal control that might be significant deficiencies or material weaknesses. We did not identify any deficiencies in internal control over financial reporting that we consider to be material weaknesses, as defined above.

Compliance and Other Matters

As part of obtaining reasonable assurance about whether the Council’s financial statements are free of material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the determination of financial statement amounts. However, providing an opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards.

Distribution

This report is intended solely for the information and use of the Council, management, and others within the organization, and the Office of Inspector General, and the United States Congress, and is not intended to be and should not be used by anyone other than these specified parties.

February 28, 2011

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APPENDIX C: MAPS OF AGENCY REGIONS AND DISTRICTS

48 Board of Governors of the Federal Reserve System 49 Federal Deposit Insurance Corporation 50 National Credit Union Administration 51 Office of the Comptroller of the Currency 52 Office of Thrift Supervision

47 THE FEDERAL RESERVE SYSTEM DISTRICTS

WA ME MT ND MN 1

VT MI NY WI 9 NH Boston SD OR WY Minneapolis 2 MA CT CA ID RI NV IA PA NJ NE MI OH 3 New York UT IL Philadelphia 7 ChicagoChicagoChicago IN Cleveland 12 MD CO DE WV San Francisco MO 4 Washington, D.C. 10 KS Kansas City St. Louis Richmond VA KY AZ 8 NC NM OK 5 AR TX TN SC MS AL GA Atlanta

Dallas LA 6

FL 11

ALASKA

HAWAII

12

48 FEDERAL DEPOSIT INSURANCE CORPORATION REGIONS (SUPERVISION AND COMPLIANCE)

WA ME MT ND MN New York

VT MI RegionNY WI NH SD OR WY MA CT CA ID Kansas City RI NV IA PA NJ NE MI UT IL OH Region IN MD CO Chicago DE San Francisco MO WV KS Region Region VA KY AZ NC TN NM OK AR TX SC MS AL GA Atlanta LA Region Dallas Region FL

ALASKA PUERTO RICO VIRGIN ISLANDS

HAWAII

GUAM

San Francisco Region New York Region

* Two area offices are located in Boston (reports to New York) and Memphis (reports to Dallas)

49 NATIONAL CREDIT UNION ADMINISTRATION

WA ME MT ND MN

VT MI NY WI NH SD OR WY I MA Albany I CT CA ID RI NV IA MI PA NJ NE UT IN OH II MD I CO IV DE MO WV Washington, DC KS V IL VA KY II AZ NC NM OK TN AR TX III SC GA MS AL Atlanta Tempe LA

FL

Austin

AMERICAN ALASKA SAMOA PUERTO RICO VIRGIN ISLANDS HAWAII

GUAM

V III

50 NCUA2 /1/11 COMPTROLLER OF THE CURRENCY DISTRICT ORGANIZATION

WA ME MT Northeastern ND MN

DistrictVT MI NY WI NH SD OR WY Central MA CT CA ID RI District New York NV IA PA NJ NE MI UT Chicago IN OH MD CO DE MO WV Washington, D.C. KS Western District Denver IL KY VA AZ NC TN NM OK AR TX SC MS AL GA Southern Dallas LA District FL

ALASKA PUERTO RICO VIRGIN ISLANDS

HAWAII

GUAM

Western District Northeastern District

51

OFFICE OF THRIFT SUPERVISION

WA ME MT ND MN Northeast

VT MI NY WI NH SD OR WY MA Central CT CA ID RI NV IA PA NE MI UT Jersey City Chicago IN OH NJ MD CO DE MO WV Western KS Washington, D.C. IL VA KY AZ NC NM OK TN AR TX SC GA MS AL Atlanta Southeast Dallas LA

FL

PUERTO RICO VIRGIN ISLANDS

Southeast

ALASKA HAWAII Western

NORTHERN MARIANA ISLANDS GUAM

52 APPENDIX D: ORGANIZATIONAL LISTING OF PERSONNEL

Organization, Douglas Foster Task Force on Examiner Education December 31, 2010 Commissioner Texas Department of Savings Dana E. Payne, Chairman (FRB) Members of the Council and Mortgage Lending Timothy Segerson, Vice Chairman (NCUA) Sheila C. Bair, Chairman Charles A. Vice Charlotte Buchanan (SLC Chair Chairperson Commissioner Representative) Federal Deposit Insurance Kentucky Department of Cheryl Davis (OCC) Corporation (FDIC) Financial Institutions Dave Freimuth (OTS) John E. Bowman, Vice Chairman Philip D. Mento (FDIC) Acting Director Office of Thrift Supervision Council Staff Officer Task Force on Information Sharing (OTS) Michael Kraemer, Chairman (FRB) Paul T. Sanford Debbie Matz Executive Secretary Dave Godwin (OTS) Chairman John Kolhoff (SLC Chair National Credit Union Representative) Administration (NCUA) Charles Lacek (FDIC) Interagency Staff Groups Robin Stefan (OCC) John Walsh Catherine Yao (NCUA) Acting Comptroller of the Agency Liaison Group Currency Sandra Thompson (FDIC) Task Force on Reports Office of the Comptroller of the Thomas A. Barnes (OTS) Robert F. Storch, Chairman (FDIC) Currency (OCC) Melinda Love (NCUA) James Caton (OTS) Daniel K. Tarullo Timothy Long (OCC) Kyle Thomas (Acting SLC Chair Member Arthur W. Lindo (FRB) Representative) Board of Governors of the Michael Stevens (SLC Chair Arthur W. Lindo (FRB) Federal Reserve System (FRB) Representative) Kathy K. Murphy (OCC) John Munn Virginia L. Phillips (NCUA) State Liaison Committee (SLC) Legal Advisory Group Chairman Michael H. Krimminger, Chairman Task Force on Supervision Director (FDIC) Thomas A. Barnes, Chairman (OTS) Nebraska Department of Deborah Dakin (OTS) Banking & Finance Timothy Long (OCC) Robert M. Fenner (NCUA) Patrick M. Parkinson (FRB) Julie L. Williams (OCC) Timothy Segerson (NCUA) State Liaison Committee (SLC) Scott Alvarez, (FRB) Sandra Thompson (FDIC) Christopher Young (SLC Chair Charles A. Vice (SLC Chair John Munn, Chairman Representative) Representative) Director Nebraska Department of Task Force on Consumer Compliance Task Force on Surveillance Systems Banking & Finance David Cotney, Chairman (SLC Robin Stefan, Chairman (OCC) David Cotney Chair Representative) Bob Bacon (SLC Chair Commissioner Luke H. Brown (FDIC) Representative) Massachusetts Division of Banks Moisette Green (NCUA) James Caton (OTS) Harold E. Feeney Calvin Hagins (OCC) Charles Collier (FDIC) Commissioner Joel Palmer (OTS) Matt Mattson (FRB) Texas Credit Union Department Paul Robin (FRB) Virginia L. Phillips (NCUA)

53 Staff Members of the FFIEC Shown are the FFIEC staff mem- bers at the Seidman Center in Arlington, Virginia, where they have their offices and classrooms for examiner education programs.

Federal Financial Institutions Examination Council staff members (from the left to right): Rosanna Piccirilli, Ernie Larkins, Cathy Pritchard, David Vallee, John Smullen, Darlene Callis, Michelle Clark, Karen Smith, Juliet Pradier, Cynthia Curry-Daniel, Paul Sanford, Melanie Middleton, and Jennifer Herring.

54