#25 - Supervising Emergency Legislation In A Pandemic

Guest: Chuck Cross, Senior Vice President of Non-Bank SupervisionHost: Matt LongacreSupervision is hard. Examiners, whether it’s for banks or nonbanks, are a unique breed. Not only must they have a mastery of financial services and the institutions that they supervise, and not only do they need a strong knowledge of what’s necessary for compliance, they must also orchestrate an extremely difficult balance between maintaining an examination procedure that is fair, impartial, and consistent from one company to another, but also continuously update their supervision based on changing circumstances and law.So, when a crisis happens, the job only gets harder. Previously on Simply Stated, we talked to experts about the impact of COVID-19 on community banks, looking at how they view their futures. We also talked to small business owners on the ground about how the CARES Act impacted their survival.Today, we’re going to talk to some experts about what it’s like to be an examiner in the middle of a pandemic. We cover the complex landscape of supervision, how an examiner begins to tackle emergency legislation, and what it takes to turn a massive piece of legislation that impacts tens of thousands of financial services businesses into a consistent, repeatable exam process that is fair to companies and consumers.Paper on Nonbank Supervision: https://www.csbs.org/sites/default/files/chapter_two_-_overview_of_state_nonbank_supervision_2.pdfCOVID-19 Consumer Relief Guide: https://www.csbs.org/mortgage-relief-coronavirusExaminer Guidance for CARES Act Examinations:Information Request - https://www.csbs.org/cares-exam-information-requestProcedures - https://www.csbs.org/cares-exam-general-proceduresReview Worksheet - https://www.csbs.org/cares-exam-loan-file-review-worksheet