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Board Report: 2015-SR-B-005 March 26, 2015

Review of the Failure of Waccamaw Bank

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Summary of Recommendations

Summary of Recommendations, OIG Report No. 2015-SR-B-005

Rec. no. Report page no. Recommendation Responsible office
1 16 Ensure that the Federal Reserve Bank of Richmond preserves departing examination staff members' supervisory records in accordance with the Board Records Retention and Disposition Schedule. Division of Banking Supervision and Regulation
2 16 Reinforce with each Federal Reserve Bank the importance of preserving departing examination staff members' supervisory records in accordance with applicable Board and Federal Reserve Bank policies. Division of Banking Supervision and Regulation
3 18 Require that the Federal Reserve Banks include a standard provision as part of future formal enforcement actions with institutions in troubled financial condition specifying the need for formal approval of material transactions. Division of Banking Supervision and Regulation
4 19

Review and update the Board's Guidelines for Appeals of Material Supervisory Determinations to establish a framework for Federal Reserve Bank Presidents and the Board to conduct appeals. In addition to any enhancements identified during the review, the framework should address

    1. the standard of review for the appeal.
    2. whether the appellant has the burden of proof to demonstrate that the material supervisory determination should be reversed.
    3. whether the party assessing the higher-level appeal is limited to reviewing the prior factual record.
    4. whether the appellant has the right to comment on the evidence providing the basis for the initial material supervisory determination, even if confidential supervisory information protections apply.
Division of Banking Supervision and Regulation
5 22 Ensure that the Board updates its appeals policy to prohibit supervisory team members from coordinating any aspect of the appeal process. Division of Banking Supervision and Regulation