The high-level credit committee announced by the office of the Comptroller of the Currency isn't the only evidence of regulatory concern about frenetic competition and relaxed loan terms. A new FDIC policy will have examiners attempting to assess a bank's lending policies during their routine exams.

The initiative's goal "is to better identify, at an early stage, any potential systemic risk to the banking system," Robert W. Walsh, the agency's manager of planning and program development in its Division of Supervision told Robert Morris Associates' Commercial Lending Newsletter.

The surveys contain 40 questions relating to underwriting standards for commercial loans, with the focus on whether the institution is tightening or loosening standards. Walsh told the newsletter that the goal is to avoid 1980s'-style woes, particularly the kind that arose in Texas. Then, he recalls, "There were reports in which the numbers looked good, but there were a few bumps that gave warnings about underwriting standards. These bumps went unnoticed."

Years later, of course, those bumps became mountains.

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