Risk-Based Supervision

DOGE’s focus on replacing humans with AI adds significance to this recent FRB OIG report on the Bank Exams Tailored to Risk (BETR) process, which tailors community bank exams to risk through model-driven off-site assessment. BETR models use forward-looking metrics to assign each institution a risk classification for each of 10 risk stripes. Each risk classification is associated with a suggested range of examination hours and tailored procedures. Examiners can then use qualitative factors to override the model-recommended classifications, hours, or procedures. The OIG report was relatively...

We provide comprehensive legal counsel to banks ranging from community institutions to the largest national and regional banks, as well as specialized trust, wealth management, and employee benefits institutions. Our services span regulatory compliance and examination support, licensing and charter applications, M&A transactions, and public policy advocacy before Congress and federal banking regulators. Capital Analysis: We assess treatment of assets, instruments, and transactions under bank or GSE capital rules. Consumer Compliance: We assist clients with compliance matters on a variety of...