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FDIC’s New Banker Engagement Site (BES): Improving CRA & Compliance Exam Communication

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This month, the Federal Deposit Insurance Corporation (FDIC) launches it new Banker Engagement Site (BES) through FDICconnect. Already reviewed by Perficient, BES provides a secure and efficient portal to exchange documents, information, and communications for consumer compliance and Community Reinvestment Act (CRA) examinations.

Specifically, BES provides a financial institution’s authorized users the ability to communicate with FDIC examination staff and to respond to the information and document requests made throughout the supervisory process, including both pre- and post-onsite examinations.

Chronology of Compliance Engagement

In the pre-personal computer age, FDIC examiners would simply show up at a bank, often by surprise, and start requesting documents from bank executives. The list was referred to as a first day letter.

By the early 1990s, the agency would mail (and very occasionally e-mail) the list of requested documents prior to the start of the onsite examination.

By the time people started speaking of Y2K, regulators were accepting documents from the bank prior to starting the onsite examination. The documents were generally minimally encrypted and therefore tended to contain non-confidential information.

Fast forward to September 2023 and the FDIC is introducing BES as the primary tool for exchanging examination planning and other information for Division of Depositor and Consumer Protection (DCP) consumer compliance and CRA activities.

FDIC Banker Engagement Site (BES) Highlights

BES offers new functionality to improve the banker pre-examination process experience and boost efficiencies through the following features:

  • The ability for bank users to collaborate with the FDIC’s examination team when responding to information and document requests;
  • The capability to submit questions and comments to the examination team;
  • The ability to view submitted responses and documents;
  • The capability to associate responses with specific requests;
  • The ability to manage the bank’s user roles and permissions;
  • The availability of informative user guides and training resources; and
  • Access to the pre-examination planning response provided for the previous examination.

RELATED CONTENT: Regulatory Reporting in Financial Services

Farewell to Enterprise File Exchange (EFX)

The FDIC’s existing tool to exchange examination information, the Enterprise File Exchange (EFX) – which still reminds viewers of green screen monitors popular when ET was the movie of the year – will be phased out. The FDIC’s DCP examination management team will inform financial institutions, during their initial pre-examination contact, of the application that will be used for their examination during the transition to BES.

BES is designed to support the consumer compliance examination process and is not planned for the use in other FDIC examinations, such as safety and soundness examinations.

BES is integrated with the FDIC’s identity access system via FDICconnect for user authentication. Bank executives and supporting third parties must be registered with FDICconnect to benefit from the enhanced capability provided by BES. Bank executives and supporting third parties will be authenticated using a secure two-factor authentication process.

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Carl Aridas

Carl is certified in the Scaled Agile Framework (SAFe), a Scrum Master, and a Six Sigma Green Belt project manager with more than 25 years of experience in financial services overseeing large-scale development global, multi-currency accounting, regulatory reporting, and financial reporting software platforms. He has hands-on experience completing, reviewing, and filing Federal Reserve, FFIEC, and IRS reports, including Call Reports, Y9C reports, 2900 reports, TIC reports, and arbitrage rebate reports.

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