Carmen J. Sullivan knows bankers will never like being regulated, but as director of compliance and consumer affairs at the Federal Deposit Insurance Corp. she hopes to make the process easier.
"I don't expect that bankers will say to me, 'I love compliance,' but there is still work we can do, and if I can make a real impact on reducing examination time and regulatory burden, I will feel good," she said in a recent interview.
She admits the FDIC's examiners were "not quite ready" when revised Community Reinvestment Act rules took effect in January.
"There was a transition period where our examiners could have used a little more training," said Ms. Sullivan. "It wasn't necessarily (the examiners') fault, because we were trying to introduce new procedures and training in a very short time, so there was no honeymoon period."
That said, Ms. Sullivan described feedback from the 122 small banks examined in January as generally positive. "The bankers who have been specific said that this examination finally focuses on what's important," she said.
Ms. Sullivan took charge of the compliance and consumer affairs division in January after its first leader, Paul L. Sachtleben, took over the agency's finance department. The division was formed in August 1994 when the FDIC combined the supervision division's compliance responsibilities with the office of consumer affairs.
Ms. Sullivan said she wants to work with banks to make compliance easier. For example, the FDIC is now notifying banks two months before an exam occurs. By yearend, she wants to shave the average time it takes to get an exam report back to a bank to 30 days from 45.
The FDIC wants to take a "reasoned, common sense-oriented" approach to exams that is based on cooperation, Ms. Sullivan said.
The eight FDIC regions also are being required to adopt uniform policies on work papers, documentation requests, and training.
"Consistency is very important," she said. "A banker should be able to expect the same scope and the same attention in the examination process regardless of wherever that person is located."
To reduce paperwork, Ms. Sullivan said examiners will try to use a single sample for each of the fair-lending and other tests conducted during an exam.
Ms. Sullivan began her FDIC career as a bank examiner trainee in 1970, after taking a government test in Minneapolis.
"In my day it was very difficult for a woman to get a professional job," she said. "So I took the government entrance examination and checked the box that said 'like to travel,' and I heard from the FDIC."
Over the next 20 years, Ms. Sullivan traveled to all 50 states. She also established a track record of working with start-up divisions within the agency.
In fact, every one of her agency jobs since 1984 has been with a newly formed department - beginning with the setting up of the Kansas City regional liquidation office.
Ms. Sullivan took a leave from the FDIC in 1989 to open the Resolution Trust Corp.'s Dallas office. In 1992, she moved to Washington to become the FDIC's director of information resources management, another new post. Before entering her current position, Ms. Sullivan spent six months as the agency's first ombudsman.
This wealth of experience with new regulatory entities gives Ms. Sullivan a somewhat philosophical view about heading the division of compliance and consumer affairs.
"Any new start-up organization requires a lot of patience and flexibility," she said. "You're just sort of supposed to go with the flow until you've gotten your sea legs."
Mr. Smith writes for Medill News Service.
