Material Loss Review of Signature Bank of New York
Emphasize to examiners in the form of training and other internal communications the requirements around timely escalation of supervisory concerns in line with the FDIC’s
forward-looking approach to supervision.
Reiterate to examiners requirements around prompt communication of risk and supervisory results to bank management, emphasizing the significance of prompt communication over linear or chronological issuance of supervisory products.
Conduct and document an evaluation of existing examination guidance to determine whether updates are warranted for:
a. The need to timely communicate findings to bank board and management even when not all supervisory findings are finalized.
b. Escalation of supervisory concerns and ratings downgrades when SRs and MRBAs have been outstanding for multiple examination cycles.
c. Specific circumstances that give rise to interim rating changes, including when concerns are known in advance of the issuance of ROEs and other supervisory
d. The effect of bank management’s and board’s lack of receptiveness and responsiveness towards the supervisory process on the rating for the CAMELS Management component.
e. Permitting the LBS Branch to review all supervisory products prior to issuance to the bank when requested, regardless if the products contain ratings information.
f. Resolution of situations in which trends between UFIRS and LIDI ratings trend differently for multiple quarters.
Reevaluate the FDIC's strategy to attract, retain, and allocate staffing, including how to enhance the supervision of large, complex financial institutions.
a. This evaluation should be documented and submitted to the FDIC’s Chairman for review and approval.
Implement target metrics and monitor variances for key supervisory outputs consistent with requirements contained in CEP Procedures, such as:
a. Supervisory Plan percentage completed to actual percentage completed to identify and take timely corrective action when examination teams are not on
track to achieve objectives detailed in annual supervisory plans.
b. Target review start date to actual review start date to identify and take timely corrective action when examination teams are not on track to achieve objectives
detailed in annual supervisory plans.
c. Number of days elapsed between target review start date and exit meeting to expectation to identify and take corrective action when reviews are not being completed and informal results communicated to the bank timely.
d. Number of days elapsed between target review start date and issuance of Supervisory Letter to expectation to identify and take corrective action when the results of reviews are not being completed and results communicated to the bank timely.
e. Number of days elapsed between year-end and ROE issuance to expectation to identify and take corrective action when ROEs are not being completed and
results communicated to the bank timely.
f. Number of days elapsed between quarter-end and issuance of Ongoing Monitoring Reports to expectations to identify and take corrective action when
ongoing monitoring is not being completed timely.
Comprehensively re-evaluate the Manual in light of the SBNY failure to determine whether updates to examination guidance are needed in the areas of:
a. stability of deposits, including large and long-term uninsured depositor relationships.
b. the velocity and magnitude of potential deposit outflows, including the supervision of liquidity stress testing.