CBA Letter Supporting S. 2237, Financial Institution’s Examination Fairness and Reform Act

The Honorable Jerry Moran                                                The Honorable Joe Manchin

U.S. Senate                                                                              U.S. Senate

521 Dirksen Senate Office Building                                    306 Hart Senate Office Building

Washington, D.C. 20002                                                       Washington, D.C. 20002


Dear Senators Moran and Manchin:


On behalf of the Consumer Bankers Association (CBA) I would like to express our support of S. 2237, the Financial Institution’s Examination Fairness and Reform Act. CBA is the voice of the retail banking industry whose products and services provide access to credit to millions of consumers and small businesses. Our members operate in all 50 states, serve more than 150 million Americans and collectively hold two-thirds of the country’s total depository assets. 


Bank examinations are an essential function of the regulatory process that oversees financial institutions and ensures compliance with regulations and adherence to safety and soundness standards.  Currently, if concerns arise during the examination process, financial institutions do not have an independent third party that is able to review their complaint and provide an impartial ruling on the supervisory action in question. 


S. 2237 would provide additional clarity to the examination process and allow banks and credit unions the right to have supervisory determinations reviewed by the Office of Independent Examination Review at the Federal Financial Institutions Examination Council.  The bill would also require reasonable time limits for examiners to provide their findings to the institutions they oversee.


CBA encourages passage of this needed legislation that will increase impartiality and help streamline the examination process for banks and credit unions. 





Richard Hunt

President and CEO

Consumer Bankers Association