Bill Overview
Title: Financial Institutions Examination Fairness and Reform Act
Description: This bill (1) sets deadlines for final examination reports and exit interviews of a financial institution by a federal financial regulatory agency, and (2) establishes the Office of Independent Examination Review to adjudicate appeals and investigate complaints from financial institutions concerning examination reports. The bill also requires the establishment of an independent internal agency appellate process at the Consumer Financial Protection Bureau (CFPB) for the review of supervisory determinations made at institutions supervised by the CFPB.
Sponsors: Sen. Moran, Jerry [R-KS]
Target Audience
Population: Employees of banks and financial institutions undergoing federal examinations
Estimated Size: 1200000
- Banks and credit unions are directly impacted as they are subject to examinations by federal agencies.
- The legislation sets specific deadlines and processes for examinations, which directly involve bank officers and employees responsible for audits and compliance.
- Consumers of banking services could be indirectly affected as the bill influences how banking institutions allocate resources to respond to federal examinations and appeals.
- Roughly 1.2 million people are employed by banks, savings institutions, and credit unions in the U.S., according to the Bureau of Labor Statistics, suggesting a substantial workforce that is directly influenced by examination practices.
- Global financial institutions with branches or operations in the U.S. may be affected by these changes.
Reasoning
- A significant portion of the target population are employees of banks and financial institutions, directly subject to examinations by federal agencies.
- Given the policy's budgetary constraints, it would primarily impact the largest institutions and possibly trickle down to affect smaller banks and credit unions either directly or through industry standards.
- A minority of the employees in this sector may be in roles less affected by this policy, such as customer service or investment advising, which do not deal with regulatory compliance or examinations.
- Consumers are indirectly impacted as changes in examination procedures could influence how banks allocate their resources. However, this impact is likely small compared to the immediate impact on bank employees.
- The policy could lead to more efficient examination processes, potentially increasing the well-being of those directly involved in compliance if stress from deadlines and procedures is reduced.
Simulated Interviews
Compliance Officer at large bank (New York, NY)
Age: 45 | Gender: female
Wellbeing Before Policy: 6
Duration of Impact: 20.0 years
Commonness: 10/20
Statement of Opinion:
- This policy helps in streamlining processes which can reduce stress related to examinations.
- I'm looking forward to having clearer timelines and procedures.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 7 | 6 |
| Year 2 | 7 | 6 |
| Year 3 | 8 | 6 |
| Year 5 | 8 | 6 |
| Year 10 | 8 | 6 |
| Year 20 | 8 | 5 |
Bank Examiner at federal agency (San Francisco, CA)
Age: 34 | Gender: male
Wellbeing Before Policy: 7
Duration of Impact: 10.0 years
Commonness: 8/20
Statement of Opinion:
- This act will make my job easier by providing structured timelines.
- I think it adds transparency which is beneficial.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 7 | 7 |
| Year 2 | 7 | 7 |
| Year 3 | 8 | 7 |
| Year 5 | 8 | 7 |
| Year 10 | 7 | 7 |
| Year 20 | 7 | 6 |
Senior Vice President at regional bank (Charlotte, NC)
Age: 52 | Gender: female
Wellbeing Before Policy: 5
Duration of Impact: 15.0 years
Commonness: 5/20
Statement of Opinion:
- The introduction of an independent review office might speed up appeals, making us more efficient.
- I hope this reduces our operational costs over time.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 5 | 5 |
| Year 2 | 6 | 5 |
| Year 3 | 6 | 5 |
| Year 5 | 7 | 5 |
| Year 10 | 6 | 5 |
| Year 20 | 6 | 5 |
Consumer Financial Services Analyst (Chicago, IL)
Age: 29 | Gender: male
Wellbeing Before Policy: 8
Duration of Impact: 3.0 years
Commonness: 12/20
Statement of Opinion:
- This policy seems necessary but doesn’t directly affect my day-to-day responsibilities.
- I’m curious if there will be any trickle-down effects on consumer services.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 8 | 8 |
| Year 2 | 8 | 8 |
| Year 3 | 8 | 8 |
| Year 5 | 8 | 8 |
| Year 10 | 8 | 8 |
| Year 20 | 7 | 8 |
Branch Manager at credit union (Dallas, TX)
Age: 41 | Gender: female
Wellbeing Before Policy: 7
Duration of Impact: 10.0 years
Commonness: 9/20
Statement of Opinion:
- I'm hopeful for clearer guidelines from the CFPB.
- Reduced ambiguity in regulatory processes might help our branch manage resources better.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 7 | 7 |
| Year 2 | 7 | 7 |
| Year 3 | 7 | 7 |
| Year 5 | 7 | 7 |
| Year 10 | 7 | 7 |
| Year 20 | 6 | 6 |
IT Specialist at multinational bank (Miami, FL)
Age: 38 | Gender: male
Wellbeing Before Policy: 8
Duration of Impact: 2.0 years
Commonness: 14/20
Statement of Opinion:
- I don't see how this policy impacts my responsibilities.
- Any improvements in examination efficiency may indirectly benefit our IT processes.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 8 | 8 |
| Year 2 | 8 | 8 |
| Year 3 | 8 | 8 |
| Year 5 | 8 | 8 |
| Year 10 | 8 | 8 |
| Year 20 | 8 | 8 |
Chief Compliance Officer at global bank (Atlanta, GA)
Age: 56 | Gender: female
Wellbeing Before Policy: 5
Duration of Impact: 20.0 years
Commonness: 7/20
Statement of Opinion:
- This policy could ease some pressure on our compliance team by defining clearer timelines.
- I'm optimistic about the establishment of an independent review office.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 6 | 5 |
| Year 2 | 7 | 5 |
| Year 3 | 7 | 5 |
| Year 5 | 7 | 5 |
| Year 10 | 7 | 4 |
| Year 20 | 6 | 4 |
Loan Officer (Los Angeles, CA)
Age: 31 | Gender: male
Wellbeing Before Policy: 7
Duration of Impact: 3.0 years
Commonness: 13/20
Statement of Opinion:
- Uncertain how this policy will impact my role.
- If our bank's compliance workload decreases, it could free up more resources for client services.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 7 | 7 |
| Year 2 | 7 | 7 |
| Year 3 | 7 | 7 |
| Year 5 | 7 | 7 |
| Year 10 | 6 | 6 |
| Year 20 | 6 | 6 |
Financial Advisor at credit union (Seattle, WA)
Age: 27 | Gender: female
Wellbeing Before Policy: 9
Duration of Impact: 0.0 years
Commonness: 15/20
Statement of Opinion:
- This policy doesn’t impact my job significantly.
- If it helps our administrative team reduce bottlenecks, it might indirectly benefit me.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 9 | 9 |
| Year 2 | 9 | 9 |
| Year 3 | 9 | 9 |
| Year 5 | 9 | 9 |
| Year 10 | 9 | 9 |
| Year 20 | 9 | 9 |
Operations Director at regional bank (Houston, TX)
Age: 50 | Gender: male
Wellbeing Before Policy: 6
Duration of Impact: 15.0 years
Commonness: 6/20
Statement of Opinion:
- The policy seems like a positive step towards improving examination processes.
- I’m hopeful it will reduce operational bottlenecks related to federal compliance.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 7 | 6 |
| Year 2 | 7 | 6 |
| Year 3 | 7 | 6 |
| Year 5 | 7 | 6 |
| Year 10 | 7 | 6 |
| Year 20 | 7 | 5 |
Cost Estimates
Year 1: $15000000 (Low: $12000000, High: $18000000)
Year 2: $15000000 (Low: $12000000, High: $18000000)
Year 3: $15000000 (Low: $12000000, High: $18000000)
Year 5: $15000000 (Low: $12000000, High: $18000000)
Year 10: $15000000 (Low: $12000000, High: $18000000)
Year 100: $15000000 (Low: $12000000, High: $18000000)
Key Considerations
- The operational readiness and funding levels for the new Office of Independent Examination Review are crucial to the bill's implementation.
- Long-term impacts on regulatory efficiency could offer cost savings not immediately apparent.
- Ensuring adequate training and adaptation to new timelines is critical to avoid compliance bottlenecks.